We highly prioritise your privacy. This policy outlines your privacy rights and our practices related to the collection, usage, disclosure, transfer, and storage of your personal data.

Definitions: In this policy, references to “InChief,” “we,” “our,” or “us” pertain to InChief A/S, JRW3 Ltd, located at Oakways House 23 The Meadway, Chelsfield, BR6 6HH, which is responsible for processing your personal data. The terms “website” and “platform” encompass all of InChief’s websites and applications.

Third-Party Websites: Please note that our platform may contain links to external websites; however, this does not indicate our endorsement of those websites. We encourage you to review the privacy policies of such third-party websites, as their procedures for collecting, handling, and processing personal data may differ from ours.

Open Platform: Given that we operate as an open platform, any reviews you write, along with your InChief profile, will be visible to all visitors on our platform. By clicking on your profile, these visitors can view your country location, all the reviews you have written or received, including the associated locations and individuals, and any photos or videos you upload. Similarly, if you are a Fan or a Follower of a Content Creator or a brand and respond to a review about their social profile, this response will also be visible on our platform. Therefore, please bear in mind that depending on the information you provide in your InChief profile and the chosen username, your anonymity may or may not be preserved. We kindly request that you refrain from being anonymous to ensure the authenticity of the feedback

Data Collection: We collect personal data, which refers to any information that pertains to an identifiable individual. When you engage in activities such as creating an InChief user account, writing a review, establishing a business or brand account on behalf of your company, or utilising our platform in any other way, we may gather and process the following personal data:

• Contact information: This includes your name, email address, and any other contact details you provide us intermittently.
• Device and location information: We collect your IP address, browser settings (including browser type, language, and time zone), and location.
• User account information: Your username, password, photo, location, and preferred language.
• Brand and Content Creator account information: This encompasses your password, Creator Social media name, domain, and any additional details you choose to include in your profile, such as information regarding the content your channel publishes.
• Usage and profiling information: We track your InChief search history, interactions with our platform, and engagement with emails we send you. This includes the time spent on our site, accessing features or functions, opening marketing emails, and clicking links.
• Review and rating information, including:
  – The social account/Creator you reviewed.
  – The product or service that you purchased and is associated with the Content Creator’s content (if applicable).
  – Your review content and star rating for a Content Creator or Brand’s social channel.
  – Product photos or videos provided by you along with your creator review or if you are the Creator the photo or video that you submit for an achievement badge.
  – The location of the reviewed Creator or Brand’s social channel.
  – Dates of review submission, edits, or deletions.
  – If requested to verify your experience with a content creator and you provide documentation, we will collect and process the documentation for the stated purpose. This may involve a dated screenshot as proof of being a fan or follower of the reviewed social channel.
  – Information about the visibility, likes, and usefulness of your review to others: We collect data on the number of readers and the perceived usefulness of your review. Additionally, we gather information when you mark someone else’s review as “useful.”

Data Collection: We collect various types of data to enhance your experience on our platform. This includes personal data related to reports and replies to reviews from your business/brand account or your Creator’s personal account. Specifically, we may collect your name, brand details, the information stated in your reply to a review, the review you reported, the reason for the report, and the date of the report.
Additionally, we gather verification data, which includes information about the verification status of your Content Creator account or business/brand profile, such as verification badges and achievements you have attained. During the verification process for Content Creators, Brands, and businesses, we may collect your first and last name, images of the submitted documents, and the number and expiration date of the documents.
Furthermore, we collect information related to questions asked on a Content Creator’s unique link. This includes details about the Creator or Brand asking the question, the content of the question, the date it was asked, and the response received from followers.

When using the “Find Content Creator” tool, Brands or Content Creators may disclose information, including but not limited to full name, phone number, email address, and reference ID. You do this at your own risk and discretion if you contact them.

Your preferences and consents, including newsletter subscriptions, email preferences, and cookie settings associated with your account, are also collected.

In terms of communication information, we retain records of communications received from you, such as review notifications, feedback, help requests, and queries via email or other electronic means. This includes associated metadata such as the time and date of the communication.

Please note that all inbound and outbound telephone calls made to or by InChief may be recorded for training, quality control, and compliance purposes. Personal data shared during phone calls, such as name and contact details, will be digitally recorded to ensure appropriate service delivery.

Lastly, if you choose to connect your InChief profile with social media platforms like Facebook, we may collect selected information from your social network, depending on the information made available and your privacy settings. This may include your name, username, email address, and profile photo.

Prior to linking your InChief profile with a social network profile, we will provide you with a notification specifying the information we will gather from that social network. You have the ability to disconnect your social network profile from your InChief profile through your InChief account whenever you wish. In such cases, InChief will eliminate your social network unique ID and sever the connection with InChief on your social network. However, your social network profile picture will persist on your InChief profile unless modified, and we will retain your name and email address. We kindly request that you refrain from sharing any sensitive personal documents or personal data, such as details regarding ethnic origin, religious beliefs, or health information, whether it pertains to yourself or others

The collection of personal data predominantly occurs through direct interaction with individuals who willingly provide their information to us for the purpose of creating an account or engaging with our platform. This encompasses particulars regarding interactions and usage patterns, such as active involvement with our platform, writing reviews, or responding to reviews within marketing emails.

We automatically collect and generate information from your device or computer as you use our services. This encompasses your IP address, location, device and browser details when accessing InChief, as well as usage and profiling data pertaining to your interactions with our platform and marketing emails.

Who is responsible for your personal data?
If you have received review invitations on InChief from a Content Creator utilising our services or from us acting on their behalf, those Content Creators are the data controllers responsible for those invitations and any associated personal data. If you have any inquiries regarding such invitations or wish to exercise your rights concerning the data used in that context, please directly contact the relevant Content Creators, as we are unable to provide assistance. Regarding all other personal data linked to our platform, such as information provided during account creation, leaving reviews, or submitting replies, InChief (JRW3 Ltd) A/S acts as the data controller.

We may utilise your personal data to: Provide our services to you, including displaying your reviews and granting access to your user account and our platform, or providing access to your Content Creator or brand account and our website.

· Identify you as a registered user when you log into our platform and revisit our platform.
· Enhance our platform and services.
· Respond to your inquiries and offer customer service.
· Send you our newsletters.
· Engage in various internal business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products and services, enhancing or modifying our platform and services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
· Train our staff for quality control purposes, aiding in the improvement of service quality.
· Exercise or comply with our own legal rights or obligations in connection with legal claims, or for compliance, regulatory, and auditing purposes when necessary. For instance, we may retain information as required by law or if compelled to do so by a court order or regulatory body.
If you possess an InChief user account, we may also utilise your personal data to:
· Verify the authenticity of your reviews.
· Invite you to submit evidence of your review. Including verifying your email address and submitting evidence that you are a true fan or follower of the Content Creator you are reviewing.
· Relay a message from the Content Creator or Brand you reviewed or the Content Creator or Brand that invited you to review content or a social account via our platform.
· Contact you if your review is flagged by a brand/business or other users, and if needed, request documentation to verify your review.
· Contact you via email to inform you about the number of times your review has been read and whether other users find it useful, or provide feedback concerning your user account or review.
· Enforce our Terms & Conditions.
· Additionally, we may employ the information in other ways for which we provide specific notice at the time of collection.

We require you to process your personal data for the following purposes:
· Perform our contractual obligations with you or the brands you collaborate with.
· Exercise and comply with our legal rights and obligations while operating an online review platform in accordance with relevant legal legislation.
· Pursue legitimate business interests related to the operation of our website and the provision of our services to you. When processing your personal data based on a legitimate interest, we ensure that the processing is relevant, sufficient, and limited to the purpose for which it was collected. Rest assured, we always take precautions to ensure that our legitimate interests do not unfairly infringe upon your rights and freedoms.
· Establish, exercise, or defend legal claims when necessary.
· In situations where you have explicitly given your consent for us to process your personal data, such as subscribing to our newsletters or accepting specific cookies on your device, you are free to withdraw your consent at any time. You can do this by using the provided functionality within the relevant product feature or by contacting us (refer to ‘Contact us’ below). However, please note that we may have the right to continue processing your information if it can be justified by one of the other legal bases mentioned above. · You have the right to object to how we process your personal data or request the restriction of processing. For further details, please refer to ‘Your rights’ below.

Who can access your personal data?
Your personal data on InChief.

We share your reviews on our platform to allow others to read about your experiences with specific Content Creators.

When you write a review, other users of our platform can view your username, location (country), all your written reviews, and any additional information you have chosen to associate with your public profile. They can also see whether you have marked other reviews as “useful.” Please bear in mind that if you have opted to use your real name as your username, it may disclose your identity. We advise you to carefully consider the information you make available on our platform and be aware that depending on the level of information provided, your anonymity may or may not be preserved. If you connect your InChief profile to a social network, details such as your profile photo, name, birth year, and approximate location will be collected from your social network profile and used to identify you on our platform. Depending on your privacy settings and the information accessible from the social network, users of our platform can utilise this information to identify the reviews you have written. If you have chosen to maintain anonymity by not using your name as your InChief username, please be aware that information from social networks can partially or fully reveal your identity and potentially identify the reviews you have written.

Your personal data on InChief when you create a brand account on behalf of your company
When you create a brand account representing your company, we will disclose your company name, company address, domain, country, and any other information you have chosen to associate with your company’s public profile. We advise you to exercise caution when deciding which information to disclose on the website, and be aware that depending on the extent of information provided, it may or may not include personal data. Other information you provide on the website, including your responses to user reviews about your social profile, is also made accessible to other users of the website. Sharing of your personal data with other services, websites, and businesses One of InChief’s primary objectives is to enhance the exposure and availability of reviews. Therefore, we permit other services to display reviews created on our platform, including but not limited to, companies/brands’ responses to reviews posted on the website. This expands the potential audience and increases consumers’ awareness of InChief and the reviews.

The categories of third-party services and companies that may display your reviews along with your public user profile (or, if you have a brand account on InChief), your responses to reviews about your brand include:

• Search engines, such as Google and Bing.
• Content Creators you reviewed on InChief.
• Content Creators who invited you to review their content.
• Consumer portals and business portals, including price comparison websites, shopping guides, etc.
• Application partners and platforms.
• Other similar websites where, in InChief’s assessment, it is relevant for users to search for reviews.

Social networks

• If you write a review on InChief in response to an invitation sent by a Content Creator via our review invitation services, that Content Creator will be able to match your review with their invitation.

Sharing of your personal data with data processors

• We share your personal data with selected third parties (including InChief’s subsidiaries and other companies within the InChief group, as well as companies we collaborate with to provide our services) who assist us in various aspects of the technical operation of our platform and the delivery of our services (“data processors”).
• These third parties act as data processors for the personal data for which we are the data controller.
• We have entered into data processing agreements with these data processors, which stipulate that they must act solely in accordance with our instructions.
• By accepting this policy, you authorise us to instruct the data processors to process data in accordance with this policy and for the purposes of utilising the platform.
• We conduct assessments to ensure that data processors have implemented reasonable technical and organisational measures to protect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access to information, as well as protection against its misuse or processing in violation of data protection laws.
• Some of these data processors and third-party services may be located in countries outside of your own country, and they may have different or less stringent data protection standards. However, in compliance with local laws in these countries, we will ensure that necessary safeguards are implemented to protect your data, regardless of the location. This is achieved through a combination of appropriate technical, organizational, and administrative security measures, as well as the implementation of necessary legal contracts to support these requirements. For instance, we will only transfer personal data of European users outside the European Economic Area if a European Commission-approved method for validating the transfer is in place

Other disclosures In addition to the above, we share your personal data with the following parties and under the following circumstances:

• To comply with laws or respond to claims, legal processes (including but not limited to court orders), and requests from public and government authorities.
• To cooperate with regulatory bodies and government authorities in connection with investigations or case referrals.
• To third parties in relation to the enforcement of our User Terms and Conditions, Guidelines for Reviews, and Terms and Conditions.
• To third parties to safeguard our operations or those of our affiliates.
• To third parties to protect our rights, privacy, safety, property, and/or that of our affiliates, you, or others.
• To third parties to pursue available remedies or mitigate damages that we may incur.
• To third parties to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our platform.
• To third parties in the event of any reorganisation, merger, acquisition, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).

How long do we store your personal data?
We retain your data only for as long as necessary or as required by law. The duration depends on the purpose for which it was collected and whether we have a continuing legal basis to retain it (such as fulfilling a contract between us, providing a requested service, meeting legal requirements, or serving our legitimate interests). Once we no longer have a valid reason to retain your data, we will either delete it or anonymise it to ensure it no longer identifies you. We handle data differently based on its usage, but you can delete your personal data or request us to do so at any time (see ‘Your rights’ below).

Personal data you provide, including your reviews, is retained for as long as you have an InChief account or as needed to provide our services to you. If you choose to delete your user account, we will keep a log containing the following information: your name, email address, and the date of account deletion. We will retain the log for three years. In certain cases, even if you delete your InChief account, we may retain some information as required by law or due to compelling legitimate interests. Reasons for longer data retention periods may include (but are not limited to) security, fraud and platform abuse prevention, compliance with legal or regulatory requirements, and protection of our legitimate business interests.

How do we ensure the security of your personal data?

• Safeguarding your personal data is our utmost priority. We employ a range of organisational, technical, and administrative measures to protect your personal data within our organisation. Regular audits are conducted to identify any vulnerabilities in our systems. However, as the internet environment is not entirely secure, we cannot guarantee the security of information transmitted to us. Please refrain from including any confidential information in emails sent via the platform, as they may not be encrypted.
• We continuously strive to enhance our security practices and policies, and as these practices evolve over time, we will update this information accordingly.

Do we use cookies?

We utilise cookies and similar technologies to assist in the delivery, optimisation, personalisation, and analysis of our services, as well as for advertising purposes.

A combination of cookies, pixels, and tracking codes is employed to gather information aligned with the purposes stated in this policy.

What is a cookie?

• A cookie is a small text file that is stored on your computer or device through your web browser at the request of the websites you visit or applications you use. Cookies store details such as your preferences and settings, which enable us to provide you with a consistent and relevant experience. Additionally, cookies help us track how you utilise our services, including any experiments or new enhancements we may test, allowing us to assess their effectiveness.
• Cookies on our website may be set by us, our collaborating third parties, or independent third parties, such as advertisers.
• What are pixels?
• Pixels are tiny, transparent image files embedded within a web page or email. We employ pixels to gain insights into your interactions with our services, including marketing emails.

What are tracking codes?

Tracking codes consist of snippets of code placed on web pages to measure various aspects, such as visits and interactions. We utilise tracking codes to gain a better understanding of how you engage with our services, the advertisements you encounter, and your overall usage of our platform.

For more information and details regarding the types of cookies and similar technologies we employ, please refer to our Cookie Policy.

· Your rights If you have an InChief user account, you have the ability to access, modify, download, or delete the essential personal data associated with your profile at any time by logging into your account.

Additionally, you can manage your email subscription preferences from the same account. You also possess certain rights regarding the personal data we hold about you. Please note that these rights may be subject to limitations, such as situations where fulfilling your request would disclose personal data about another individual or when we are obligated by law or have compelling legitimate interests to retain certain information. If you have unresolved concerns, you have the right to file a complaint with a data protection authority. For detailed instructions on how to do so, please refer to the Privacy section in our Support Centre. Accessing and downloading your personal data If you have an InChief user account, you can log in to view and download information related to your account, including your reviews.

If you possess a brand account on InChief or do not have an account at all, you may send an email to Info@InChief.com to request information regarding your personal data. Correction and deletion of your personal data Should any of the personal data we hold about you be inaccurate or misleading, or if there are changes to your personal data or you wish to be removed from the platform, you have the option to correct, modify, or delete the information through your InChief user account.

Alternatively, you can email Info@InChief.com to request the correction or deletion of your information. For additional information on deleting your data, please refer to the ‘How long do we store your personal data?’ section.

Other rights In addition to the aforementioned rights concerning your personal data, you also have the right to object to the processing of your personal data and to have the processing of your personal data restricted. This particularly applies when we are not obligated to process the data to fulfil a contractual or legal requirement, such as the processing of your personal data for direct marketing purposes. If we have obtained your consent for certain processing activities, you have the right to withdraw your consent at any time. You can withdraw your consent either through the provided functionality within the relevant product feature or by contacting us (refer to ‘Contact us’ below). Please note that withdrawing your consent for InChief to process your data will not impact any processing that has already taken place.

Children’s Information: Our platform is not intended for children under the age of 16, and we do not knowingly collect personal data from such individuals. If you become aware that a child under the age of 16 has provided us with their personal data, please contact us using the provided contact information.

Changes to this policy: Occasional updates to this policy may be necessary due to evolving laws, regulations, industry standards, or changes to our services or business. We will post any changes to this page and encourage you to review our Privacy Policy periodically to stay informed. In the event of significant alterations that affect your privacy rights, we will provide additional notice, such as via email or through our platform. By continuing to use our platform or services after we have published or sent a notice regarding the policy changes, you signify your acceptance and agreement to the updated policy.
Contact us: We aim to provide clarity and transparency regarding the processing of your personal data. If you have any questions about how we handle your personal data or wish to exercise your rights under our policy, please feel free to contact our Data Protection Officer at Info@InChief.com.

You can also reach us by mail at: InChief Oakways House, 23 The Meadway Chelsfield, BR6 6HH If contacting us by email does not resolve your complaint