- About us
- General information about how we process Users’ data
- How do we safeguard children’s privacy?
- What do we do with Users’ data?
- How do we share Users’ data?
- How do we transfer Users’ data internationally?
- How do we secure Users’ data?
- How long do we retain Users’ data?
- Your legal rights
- Location-specific rules
1. About us
SuperAwesome Trading Limited (referred to herein as “SuperAwesome,” “us”, “our” or “we”) is a private limited company incorporated in England (Company Number: 03885555), having its registered office at 2-4 Packhorse Road, Gerrards Cross, Buckinghamshire, England SL9 7QE.
About the Engagement Dashboard
The Engagement Dashboard is SuperAwesome’s channel management and administration tool.
SuperAwesome operates two child-directed media services: PopJam and Rukkaz. These services deliver channels that are created, run and managed by a variety of channel owners: advertisers, agencies, and the parents, legal guardians or agents of social media influencers.
The Engagement Dashboard enables these channel owners to manage their channel, share their content on their channel, interact with their PopJam or Rukkaz users, and monitor the performance of their content (e.g. engagement rates and the number of impressions).
Our contact details
Full name of legal entity: SuperAwesome Trading Limited
Email address: firstname.lastname@example.org
Postal address: 2-4 Packhorse Road, Gerrards Cross, Buckinghamshire, England SL9 7QE
Telephone number: + 44 (0) 203 668 6677
- “Partner” – a channel owner. This can be a brand, advertiser, agency, adult social media influencer, or the parent, legal guardian or agent on behalf of a social media influencer. In this case, an influencer is typically one of a subset of PopJam or Rukkaz users with whom we or an advertiser have a business arrangement whereby, if the user is under the age of digital consent, we have obtained verified parental consent to make their personal information (including their photo and actual name) visible on PopJam or Rukkaz. The channels of influencers who are below the age of digital consent must be managed by their parent, legal guardian or agent, and signed agreements must be in place.
- “Parent” – the parent or legal guardian of an influencer who is under the age of digital consent.
- “User” – a person who accesses the Engagement Dashboard in order to manage a channel as or on behalf of a Partner.
3. General information about how we process Users’ data
Our right to process Users’ data
We only process Users’ data when we have a legal basis to do so, in any of the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with a Partner
- Where it is necessary for our legitimate interests (or those of a third party) and the User’s interests and fundamental rights do not override those interests
- Where we need to comply with a legal obligation
Note that we may process a User’s data for more than one lawful basis, depending on the specific purpose for which we are using their data. For more information, contact us at email@example.com.
When we refer to our “legitimate interests”, we mean the interest of our company (SuperAwesome) in conducting and managing our business to enable us to give Users the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact (both positive and negative) on Users and Users’ rights before we process their personal data for our legitimate interests. We do not process a User’s data for activities where our interests are overridden by the impact on the User (unless we have their consent or are otherwise required or permitted to by law).
For further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities, contact us at firstname.lastname@example.org.
Special category data
Except for Partner Content, which may contain such data, we do not process any special categories of personal data (as defined in GDPR) about Users; for example, data about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic or biometric data, and criminal convictions or offences.
Change of purpose
We will only process a User’s data for the purposes for which we originally intended, unless we reasonably consider that we need to process it for another reason and that reason is compatible with the original purpose.
For an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com.
We may process a User’s data without their knowledge or consent, in compliance with the rules in Our right to process Users’ data, where this is required or permitted by law.
We collect, use and share aggregated Users’ data such as statistical or demographic data to improve the Engagement Dashboard. Aggregated data will not directly or indirectly reveal the identity of a User.
For example, we may aggregate usage data to calculate the percentage of Users accessing the Engagement Dashboard after they have downloaded the application.
- When a Partner first signs up to use the Engagement Dashboard, we get their permission (via email or call) to send them newsletters periodically. A newsletter may include an optional survey. Newsletters are sent via Hubspot, which enables Partners to unsubscribe at any time, after which they no longer receive newsletters.
- Partners receive service information updates via the Engagement Dashboard.
4. How do we safeguard children’s privacy?
SuperAwesome’s Engagement Dashboard is not designed for use by children aged under 13. Where a social media influencer who is below the age of digital consent wishes to run a channel, their Parent or an authorised agent must enter into a contract with SuperAwesome, which confirms their authority to act on the influencer’s behalf and to manage their channel.
As with all of SuperAwesome’s products and services, the Engagement Dashboard is subject to periodic technical and legal review through its Compliance Committee comprising our Chief Privacy Officer, Chief Technology Officer and its Information Security and Legal teams.
5. What do we do with Users’ data?
When a Partner enters into a contract with SuperAwesome to use the Engagement Dashboard, the Partner is (under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) the data controller of any personal data entered into the Engagement Dashboard, including that of any Users, and is responsible for informing SuperAwesome of any changes required should a User’s access need to be added or revoked.
SuperAwesome is a data processor (under GDPR) which processes personal data in the Engagement Dashboard on behalf of the Partner in order to support them in meeting their legal responsibility to operate safe channels and process data in accordance with applicable legal requirements.
What Users’ data do we process?
|When we process a User’s data||How we describe that data in this policy||What the data includes|
|When someone enquires about our products or services, subscribes to our service or publications, or gives us feedback.Contact details may be provided by filling in forms or by corresponding with us.||Contact data||Company name, email address.|
|When a User accesses the Engagement Dashboard as or on behalf of a Partner.||User Access Data||First name, last name, email address and password.|
|When a User enters channel content into the Engagement Dashboard as or on behalf of a Partner.||Partner Content||Any content, including but not limited to brand names, Partner trademarks, text, images, assets, artwork, designs and videos, comments, communications, posts, information and any other content or materials posted, uploaded or otherwise made available through the Engagement Dashboard. |
|When a User interacts with the Engagement Dashboard, we collect technical data about their equipment, browsing actions and usage patterns We collect this data using cookies, server logs and other similar technologies.||Technical Data||Internet protocol (IP) address, login data, browser type and version, time zone setting, country and language, browser plug-in types and versions.|
|When a User interacts with the Engagement Dashboard.||Analytics||Channel-specific non-technical PopJam/Rukkaz user session lengths.Retention and general usage of the Engagement Dashboard.Anonymous pop-up survey responses. Users can rate their experience from 1 to 10 and optionally submit a message.|
Channel names are created either by the Partner or by SuperAwesome upon request and must be appropriate for children to see. Influencers under the age of digital consent may use their actual name for their channel, subject to a signed agreement from their Parent or agent.
Partners may see the usernames and comments of PopJam or Rukkaz users on their content within their Engagement Dashboard. Otherwise Partners do not have access to any user data that may directly or indirectly identify an individual.
We collect, use and internally share aggregated data such as statistical or demographic data to improve our Engagement Dashboard. For example, we may aggregate usage data to calculate the percentage of Users accessing a specific Engagement Dashboard feature.
We may derive aggregated data from personal data. However, because this data has been through a process to de-identify personal data (so that it can no longer be associated with an individual), the aggregated data will not directly or indirectly reveal the identity of any living person.
What is our legal basis for processing Users’ data?
We have set out below a description of the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose for collecting personal data||How we describe that data in this policy||Lawful basis for processing personal data|
|To facilitate channel registration and access to the Engagement Dashboard.||User Access Data||The performance of our contractual obligations with Partners.|
|To facilitate Partner Content uploads to PopJam or Rukkaz.||Partner Content||The performance of our contractual obligations with Partners.|
|To use data analytics to improve the Engagement Dashboard, customer relationships and user experiences.||Technical Data and Analytics||Necessary for our legitimate interests to operate, maintain and improve the Engagement Dashboard.|
6. How do we share Users’ data?
Sharing Users’ data with third-party providers
The Engagement Dashboard uses third party data processors, some of whom may process personal data. For example, we use a third party to host the Engagement Dashboard and we use third party tools to help us better understand how customers and their employees navigate across the Engagement Dashboard. We enter into contractual arrangements with our service providers to ensure that they are only processing data in a lawful manner.
The third parties contracted by SuperAwesome to process personal data on our behalf are set out in the table below:
|Amazon Web Services EMEA SARL||Storage of Engagement Dashboard data.||AWSPP|
|Amplitude, Inc.||Engagement Dashboard analytics on events generated from user actions.||APP|
|Userguiding||Tutorials, latest feature news and satisfaction surveys||PP|
You can learn more about how our third party data processors use data by reading their privacy policies.
Sharing Users’ data within SuperAwesome
Sharing Users’ data for other reasons
We may disclose a User’s data for any of the following reasons:
- in the good faith belief that we are required to do so by law
- if doing so is reasonably necessary to comply with legal process
- to permit us to pursue available remedies, including commencing or responding to any claims
- to enforce the terms and conditions of a Partner agreement
- to protect the rights, property, or personal safety of SuperAwesome or the public
- to prevent other illegal activity
- for risk management purposes
7. How do we transfer Users’ data internationally?
We may transfer Users’ data in the following ways:
- We share Users’ data within the SuperAwesome group of companies. This involves transferring Users’ data outside the European Economic Area (EEA).
- Some of our third-party data processors are based outside the EEA so their processing of Users’ data may involve a transfer of data outside the EEA.
Whenever we authorise a transfer of your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by using specific contracting frameworks approved by the European Commission which give personal data the same protection it has in Europe.
For further details, see the European Commission: Model contracts for the transfer of personal data to third countries. If you require further information on the specific mechanism used by us when transferring your personal data out of the EEA, please contact us at firstname.lastname@example.org.
8. How do we secure Users’ data?
SuperAwesome values your trust and strives to maintain adequate security measures for all areas of our business and our services. Since the Engagement Dashboard is a service that operates digitally, SuperAwesome is continuously reviewing and improving its security measures to prevent data breaches and security incidents.
- We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
- We limit access to your personal data to those employees, agents, contractors and other third parties strictly on a need to know basis. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
- We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Some of the correspondence you receive from us may contain links to and from third party websites, online services or mobile applications that are not affiliated with or operated by us, including those of the Partners who use the Engagement Dashboard. While SuperAwesome tries to link only to websites that share our high standards and respect for privacy, we are not responsible and accept no liability for the content, security or privacy practices of those other websites.
To find out how your personal data may be used by third-party websites, refer to the privacy and cookie policies displayed on those websites.
9. How long do we retain Users’ data?
We only retain Users’ data for as long as is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain a User’s data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with the User.
To determine the appropriate retention period for personal data, we consider:
- the amount, nature and sensitivity of the personal data
- the potential risk of harm from unauthorised use or disclosure of your personal data
- the purposes for which we process your personal data and whether we can achieve those purposes through other means
- any applicable legal, regulatory, tax or accounting requirements
In some circumstances we may apply a process to de-identify your personal data (so that it can no longer be associated with you) and on an aggregated basis may use it for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. For example you will have rights to:
Review/access/delete/restrict the collection of your child’s personal data. Under COPPA, a Parent has certain rights over how we handle the personal data of their child. This includes the right for a Parent to review, access, or delete the personal data that has been collected by us in connection with their child.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent as the legal basis upon which to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us. If you are a California resident, please refer to our California Residents section below for more information on your legal rights.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Do Not Track disclosure
Your browser may allow you to set a Do Not Track (DNT) signal indicating that you do not wish your online activity to be tracked. Currently, the Engagement Dashboard does not support and does not act on DNT signal headers that we may receive.
11. Location-specific rules
Depending on where you are resident specific rules apply:
UK and EU
If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact the Information Commissioner’s Office (www.ico.gov.uk) which is the regulator responsible for data protection in the United Kingdom, where SuperAwesome Trading Limited is located (Registration number Z8630714)
Alternatively, if you are located outside of the United Kingdom, you may contact your local data protection authority. You can find contact details here.
If you are a resident of the United States and believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB Privacy Certified at email@example.com or by using their online contact form at: https://www.esrb.org/privacy/contact.
For the purposes of this section:
Personal Information and Service Provider have the meanings assigned to them under the California Consumer Privacy Act of 2018, (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations (CCPA).
In the past 12 months, SuperAwesome, or its third parties, have collected the following categories of Personal Information using the categories enumerated in the CCPA:
- IP address and device ID
- Name, email address or telephone number if you’ve contacted SuperAwesome with an inquiry (collected by SuperAwesome only)
In the preceding twelve months, we have not sold any California resident’s Personal Information.
Right to know and access. If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the following information:
- The specific pieces of Personal Information we have collected about you during the last 12 months;
- The categories of Personal Information we collected, sold or disclosed for a business purpose about you within the last 12 months;
- The categories of sources from which the Personal Information was collected;
- The purposes for which the information was collected or sold; and
The categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared.
Because SuperAwesome is a Service Provider, we may not be able to respond directly to your request; in this case, we will direct you to contact the Partner for additional information. Where possible, we will provide this information to you in a readily usable format that allows transmission to another entity. To submit a request, click here to access our online web form or email us at firstname.lastname@example.org. We will confirm your request within 10 days of receipt.
Right to delete. Because SuperAwesome is a Service Provider, we may not be able to respond directly to your request; in this case, we will direct you to contact the applicable third party for additional information. If you are a California resident, you may submit a verifiable request for us to delete any personal information we have collected about you. To submit a request, please email us at email@example.com or please use this webform.
Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. If we need additional information to verify your identity, we will contact you to request that information.
Right to be free from discrimination. We will not discriminate against you because you have chosen to exercise your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.
Exercising your rights. To submit a verifiable request or to otherwise contact us for more information about how to exercise your rights, please follow the instructions above. If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent is able to (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.
California residents “Shine the Light” Law
We do not share your personal information with any unaffiliated third parties for their own marketing purposes.