1. What is this document and why should you read it?
This Privacy Notice explains how and why Imperial Leisure Limited, the operators of authenticity.media (“Imperial Leisure”, “we”, “our” and “us”), collects, uses, discloses and otherwise processes personal data about individual users of our website www.authenticity.media (the “Website”) or mobile applications (the “App”), and those that access our services through APIs and through third-parties (collectively, the “Services”), including Website Users, Brands and Creators (whether prospective, current or past), and people that apply to work with us (together, “you”).
This Privacy Notice does not address data that is not subject to applicable data protection laws (such as deidentified or publicly available information). This Privacy Notice is also not a contract and does not create any legal rights or obligations not otherwise provided by law.
You should read this Privacy Notice so that you know what we are doing with your personal data.
2. Our data protection responsibilities
“Personal data” is any information that relates to an identifiable natural person. Your name, address and contact details are examples of your personal data, if they identify you.
The term “process” means any activity relating to personal data, including collection, storage, use and transmission.
Whether you are a Brand, a Creator, a Website User, or a Job Applicant for a vacancy at authenticity.media (or a combination of those, as such terms are defined below), authenticity.media is a “controller” of your personal data. This means that we make decisions about how and why we process your personal data and are responsible for making sure it is used in accordance with data protection laws. This Privacy Notice describes our privacy practices where we are acting as the controller of personal data. However, this Privacy Notice does not cover or address how our Creators may process personal data when they provide their services.
3. What types of personal data do we collect and where do we get it from?
If you are reviewing this Privacy Notice, then you will fall into at least one of the following categories of individuals about whom we process personal data:
- prospective, current or past customers of authenticity.media who register an account and/or post an Opportunity (“Brands”);
- current or past individuals or businesses that register as a Creator on authenticity.media to provide a service to Brands, or businesses who we identify as being of interest to our Brands and who we may then contact with potential business opportunities relating to our Brands (“Creators”);
- individuals that access our Website (“Website Users”); and/or
- individuals applying for a job with us (“Job Applicants”).
Accordingly, we will collect and process different types of personal data about you depending on which of these categories are relevant to you. The different types of personal data that we collect and the sources we collect it from are summarised below.
4. Personal Data Categories
Depending on how you use our Website and Services, we will collect different types of personal data about you. This data might include your name, contact details, details about your business, any information you provide in correspondence with us, records of your activity with us, and how you use our Services. We need these details to provide our Services to you. We have set out more specific details on the categories of personal data we collect and process about Brands, Creators, Job Applicants, and Website Users in Table A below.
We and our trusted third-party partners may collect personal data automatically through technologies like cookies, beacons, pixels, scripts and SDKs about the devices and computers you use when you interact with our Website, App and other Services, such as browser type, device type, language, operating system, the referring web page, pages visited, and hyperlinks clicked (collectively, “Usage Information”). We may also use third-party tools to collect Usage Information you provide to us or information about how you use the Service and may monitor and record your mouse movements, scrolling, clicks and keystroke activity on the Service and other browsing, search or purchasing behaviour. These tools may also record Usage Information you enter when you interact with our Services or engage in chat or form features through our Services.
We may also collect personal data from other sources and third parties. For example, this data could be from our Website, your business website, as well as social media. More details about the sources from which we obtain personal data about Brands, Creators, Job Applicants, and Website Users can be found in Table B below.
5. How do we use your personal data and why
We process your personal data for particular purposes, which are relevant to your relationship and engagement with us. We are required by law to always have a “lawful basis” for processing your personal data.
We use the personal data we collect for a number of different reasons, including to provide our Services to you or with you, to communicate with you, to verify your identity, to make sure our Website and Services are functioning properly and provide the best services for you, to keep accurate records and for legal reasons.
We rely on a number of different lawful grounds or ‘bases’ in order to process your personal data. These include that we have your consent to the processing, we need to process your personal data to enter into or perform a contract with you, we need to process your personal data to comply with our legal obligations, and/or the processing is necessary for our legitimate interests (or the legitimate interests of a third party).
More details on the purposes for which we process personal data on Brands, Creators and Website Users, and the lawful bases we rely on can be found in Table C below.
We may also receive, convert, or process your personal data to create deidentified, statistical, or aggregated information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. We do this to better protect your privacy, or so that you are not identified or identifiable from it. We may use such data to conduct research and analysis, including to produce statistical research and reports and for other purposes outside of the scope of this Privacy Notice. For example, to help us understand and improve the use of our Website.
6. Who do we share your personal data with and why?
Our core Service is the facilitation of introductions between Brands and Creators. In order to perform these Services, we will share information submitted in an Opportunity (including the Brand name, email address and phone number) with relevant Creators where such Creators elect to respond to the Opportunity. A Brand may also choose to share their personal information directly with a Creator when communicating with them via our Website.
We may use certain trusted third party companies and individuals to help us provide, analyse, and improve our Services (including but not limited to Brand/Creator verification, data storage, maintenance services, web and SMS communications, database management, web analytics, and improvement of our Services). These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties so that they can perform those necessary functions.
We may also share your information with third parties who then use your personal data for their own purposes. For example, where you choose to access our Services through such an application. These organisations will also use your personal data for their own, separate purposes (also as a “controller”) – they will have their own privacy notices which you should read, and they have their own responsibilities to comply with applicable data protection laws.
In certain circumstances, where necessary for the purposes set out here, we will also disclose your personal data to:
- authenticity.media affiliates;
- consultants and professional advisors including legal advisors, auditors and accountants;
- business partners and joint ventures;
- a prospective seller or buyer of our business and their advisors or in connection with a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets;
- insurers;
- courts, court-appointed persons/entities, receivers and liquidators;
- third parties such as legal advisors and law enforcement where necessary to comply with a legal obligation, to enforce a contract, to prevent fraud or to protect the rights, property or safety of our employees, customers or others;
- to governmental departments, local government, statutory and regulatory bodies including (in the UK) the Information Commissioner’s Office, the police and His Majesty’s Revenue and Customs;
- with your consent or at your direction, we may disclose your personal data to certain other third parties or publicly;
- our marketing providers in order to advertise and communicate with you about the Services;
- with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information automatically from your browser or device when you visit our websites and other services through the use of cookies and related technologies;
- your employer or colleagues if you interact with our Services in connection with your employment; and
- trusted third party platforms that may promote a Creator’s profile in order to facilitate introductions of prospective Brands to Creators.
7. Where is your personal data transferred to?
When we share personal data about you, as set out above, this may include a transfer of your personal data to recipients outside the UK. If any disclosures of personal data mean that your personal data will be transferred outside the European Economic Area, we will only make that transfer in accordance with our obligations under applicable data protection laws.
8. How long do we keep your personal data for?
We will only retain your personal data for a limited period of time and for no longer than is necessary for the purposes for which we are processing it for (including as necessary to comply with our legal or regulatory obligations, resolve disputes, and enforce our agreements).
Once retention of the personal data is no longer reasonably necessary for the purposes outlined in Table C, we will either delete or deidentify the personal data or, if that is not possible (for example, because personal data has been stored in backup archives), we will securely store the personal data and isolate it from further active processing until deletion or deidentification is possible.
9. What are your rights in relation to your personal data and how can you exercise them?
You have certain legal rights in relation to any personal data about you which we hold. If you have any concerns or queries about this notice or how we process your personal data, please contact us using the details below. Each of these rights are subject to certain conditions and vary depending on your location or residency. Please refer to Table D below for information about your rights and the additional privacy choices that may be available to you.
The following privacy choices are made available to all individuals with whom we interact:
a. Communication Preferences
You may adjust the settings for receiving communications from us at any time by visiting the ‘notifications’ section of your profile, or clicking ‘unsubscribe’ in any email you receive from us.
b. Automatic Data Collection Preferences
Certain of our Services may provide you the ability to adjust your preferences regarding our use of automatic data collection technologies that process Usage Information. For example, depending on where you are accessing the Services, there may be a “Cookie Preferences” manager linked in the footer of our Websites that allows you to adjust your preferences regarding certain automatic data collection technologies on the specific Website you are visiting. Note any cookie preferences you express will only apply to the specific device and browser you are using at that time (which means you will need to change your preferences on each device and browser you use to interact with the specific Website you are visiting).
c. Targeted Advertising Preferences
We engage third parties to help us facilitate targeted advertising designed to show you personalized ads based on predictions of your preferences using personal data, including Usage Information. The data we and our third-party partners use for purposes of facilitating targeted advertising, and ancillary activities, are collected through the use of a variety of automatic data collection technologies, including cookies, web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help link the personal data we and our third-party partners collect to the same person, or otherwise target advertising to an individual on a third-party website or platform.
10. Additional Region-Specific Privacy Disclosures
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain U.S. states. If you are a resident of the United States, please see the Additional U.S. Privacy Disclosures in Table D below.
11. Children’s Personal Data
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 18. If an individual is under the age of 18, they should not use our Services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 18 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 18, we will promptly delete that personal data. Where a service category on the Website caters for children under the age of 18, only the personal data of the parent or guardian should be submitted to receive responses from interested Creators.
12. Third-Party Websites and Services
Our Services may include links to third-party websites, plug-ins, applications and other services. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to any personal data practices of third parties. To learn about the personal data practices of third parties, please visit their respective privacy notices.
13. Updates to this Privacy Notice
We may update this Privacy Notice from time to time to reflect changes to the type of personal data that we process and/or the way in which it is processed. We also encourage you to check this Privacy Notice on a regular basis.
14. Contact Us
If you want more information about any of the subjects covered in this Privacy Notice or if you would like to discuss any issues or concerns with us, you can contact us at privacy@authenticity.media.
15. Cookies
15.1 A “cookie” is a small text file that a website sends to your browser, which your browser stores on your device. Cookies allow a website to recognise your browser, remember your preferences, and collect information about how you use the site.
15.2 We use two types of cookie by duration:
- Session cookies — temporary cookies that are deleted automatically when you close your browser.
- Persistent cookies — cookies that remain on your device until they reach their expiry date or you delete them manually.
15.3 We use cookies and similar technologies to keep the platform working correctly, understand how it is used, remember your preferences, and — where you have given your consent — to deliver relevant advertising. The categories of cookies we use and their purposes are set out in Table F below.
15.4 Managing your cookie preferences. Where our Services provide a Cookie Preferences manager (linked in the footer of our Website), you can use it to accept or decline non-essential cookies by category. Any preferences you set apply only to the specific device and browser you are using at that time; you will need to set preferences separately on each device and browser you use. You can also control cookies through your browser settings — see www.allaboutcookies.org for guidance. Please be aware that disabling certain cookies may affect the functionality of our platform.
15.5 Some cookies on our platform are set by trusted third-party services we use, such as analytics and advertising providers. Those third parties operate under their own privacy and cookie policies, which we encourage you to read. We may update the list of third-party providers in Table F from time to time as our use of services changes; material changes will be indicated by a notice on our Website.
15.6 For opt-out options in relation to targeted advertising cookies, please see section 9c of this Privacy Notice or use the Cookie Preferences manager in the site footer.
Table A – Personal Data Categories
The following table describes the categories of personal data we collect and process about Brands, Creators, Website Users, and Job Applicants.
| Category | Description | Collected from |
|---|---|---|
| Contact Data | Basic contact and identity information (e.g. name, email address, phone number, address) | Brands, Creators, Website Users, Job Applicants |
| Communication Data | Communications, images, videos and documents you share with us; your contact and marketing preferences | Brands, Creators, Website Users, Job Applicants |
| Account Data | Profile details, usernames, passwords, activity history, referral data, usage analysis | Brands, Creators |
| Brand or Creator Content | Files, documents, audio, videos, images, credentials, service information, reviews and ratings submitted through the Services | Brands, Creators |
| Interaction Content | Transcripts of chat logs between Brands and Creators where transmitted via our platform | Brands, Creators |
| Opportunity Data | Opportunity details, responses, usage feedback, ratings of Creators | Brands, Creators |
| Event, Contest, Promotion, and Survey Information | Data collected when you sign up for events, contests, surveys, or submit testimonials | Brands, Creators, Website Users |
| Feedback and Support Information | Messages submitted via forms, chat or email; call recordings where legally permitted | Brands, Creators, Website Users, Job Applicants |
| Security-Related Information | Visitor names, contact info, premise video recordings, electronic access logs | All categories (where applicable) |
| Device and Network Information | Device type, operating system, IP address, browser data, carrier information, timestamps | Brands, Creators, Website Users |
| Service Usage Information | Browsing behaviour, page visits, content interactions, and activity captured via third-party technologies | Brands, Creators, Website Users |
| Geolocation Data | Approximate location derived from device information or IP address; precise location only with your permission | Brands, Creators, Website Users |
| Analytics Data | Service usage monitoring, technical administration data, functionality verification | Brands, Creators, Website Users |
| Creator Data | Service details, profile information, activity history | Creators |
| Job Application Data | Information submitted as part of an employment application | Job Applicants |
Table B – Sources of Personal Data
| Category of individual | Types of personal data | Sources |
|---|---|---|
| Brands | Contact Data, Communication Data, Account Data, Opportunity Data, Device and Network Information, Service Usage Information, Geolocation Data, Analytics Data | You; our Website (including cookies); your device; third-party sources (social media, search engines, online maps, marketplaces, review sites, directories) |
| Creators | Contact Data, Communication Data, Creator Data, Device and Network Information, Service Usage Information, Geolocation Data, Analytics Data | You; your employer; the Services (including cookies); your website; your device; third-party sources (social media, search engines, maps, marketplaces, review sites, directories) |
| Website Users | Contact Data, Communication Data, Device and Network Information, Service Usage Information, Geolocation Data, Analytics Data | You; the Services (including cookies); your device |
| Job Applicants | Contact Data, Communication Data, Job Application Data | You |
We may also receive personal data about you from other users (for example, if another user refers you to our Services or leaves a review), or we may generate inferences about your interests and preferences based on information we have collected about you.
Table C – Purposes and Lawful Bases for Processing
| Purpose of processing | Consent | Contract performance | Legal obligation | Legitimate interests |
|---|---|---|---|---|
| Communications with you | ||||
| Corresponding with you, including responding to requests, enquiries, and complaints | ✓ | ✓ | ✓ | |
| Confirming and processing Opportunities or fulfilling contractual obligations and delivering Services | ✓ | ✓ | ||
| Sending Service information and direct marketing | ✓ | ✓ | ||
| Administering, improving, and personalising Services | ✓ | |||
| Identity and Verification | ||||
| Performing ID and verification checks | ✓ | ✓ | ✓ | |
| Website and Service Operation | ||||
| Ensuring Website operation and diagnosing technical problems | ✓ | |||
| Identifying approximate geographical location | ✓ | |||
| Monitoring and analysing Services usage | ✓ | |||
| Facilitating account setup and use | ✓ | ✓ | ✓ | |
| Brands and Creators | ||||
| Dealing with Opportunity requests | ✓ | ✓ | ||
| Recommending suggested matches | ✓ | |||
| Understanding user engagement and conducting analytics | ✓ | |||
| Sharing Creator feedback and statistics with prospective Brands | ✓ | |||
| Enabling Creators to provide services to Brands | ✓ | ✓ | ✓ | |
| Sharing contact information where consent has been given for third-party contact | ✓ | |||
| Onboarding Brands and/or Creators (including verification checks) | ✓ | ✓ | ||
| Moderating communications between Brands and Creators | ✓ | |||
| Analysing sentiment and outcomes of interactions | ✓ | |||
| All categories | ||||
| Establishing and enforcing legal rights, monitoring for security incidents and fraud, and protecting rights and property | ✓ | ✓ | ||
| Complying with law enforcement, regulatory requests, and court orders | ✓ | ✓ | ||
| General record-keeping and relationship management | ✓ | |||
| Keeping legally required records and evidence of compliance | ✓ | |||
| Managing the sale, restructuring, or merger of the business | ✓ | |||
| Defending rights, enforcing contracts, and resolving disputes | ✓ | ✓ | ||
Table D – Your Rights
Rights available to UK and EEA residents
| Right | Description |
|---|---|
| Right of access | You may request confirmation of whether we process your personal data and, if so, obtain a copy of the personal data we hold about you along with information about how we use it. We may need to verify your identity before responding. |
| Right to data portability | Where we process your personal data based on your consent or to perform a contract, and the processing is carried out by automated means, you may request that we provide your personal data to you in a structured, commonly used, machine-readable format. |
| Right to correction | You may request that we correct any inaccurate or incomplete personal data we hold about you. You can update certain information directly through your account profile. |
| Right to object | You may object to our processing of your personal data where we rely on legitimate interests as our lawful basis. You always have the right to object to our use of your personal data for direct marketing purposes. |
| Right to restrict processing | You may ask us to restrict the processing of your personal data in certain circumstances (for example, while we verify the accuracy of data you have disputed). |
| Right to erasure | You may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, or where processing is unlawful. This right is subject to certain exceptions (for example, where we need to retain data to comply with a legal obligation or to establish, exercise or defend a legal claim). |
| Right to withdraw consent | Where we rely on your consent to process your personal data, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. |
To exercise any of these rights, please contact us at privacy@authenticity.media. We may need to verify your identity before responding to your request. We will respond within one month of receiving a valid request (which may be extended by a further two months in complex cases).
Additional rights for US residents
Depending on the US state in which you reside, you may have additional rights under applicable state privacy laws (including the California Consumer Privacy Act and similar state laws). These may include:
| Right | Description |
|---|---|
| Right to know | You may request details of the categories and specific pieces of personal data we have collected about you, the sources from which it was collected, the purposes for which it is used, and the categories of third parties with whom it is shared. |
| Right to correct | You may request that we correct inaccurate personal data we hold about you. |
| Right to delete | You may request that we delete personal data we have collected from you, subject to certain exceptions. |
| Right to opt out of sale or sharing | You may direct us not to sell or share your personal data for cross-context behavioural advertising. |
| Right to opt out of targeted advertising | Depending on your state of residence, you may have the right to opt out of the processing of your personal data for targeted advertising purposes. |
| Right to non-discrimination | We will not discriminate against you for exercising any of your privacy rights. |
To submit a request, please contact us at privacy@authenticity.media. Please include your name, email address, phone number, and your state of residency. We may need to verify your identity before processing your request. If you use an authorised agent to submit a request on your behalf, we may require a signed authorisation or power of attorney.
Table E – Third Parties
The following categories of third parties may receive your personal data in connection with the services described in this Privacy Notice:
| Category of third party | Role | Types of data shared |
|---|---|---|
| Website analytics providers | Help us understand how our Website is used | Device and Network Information, Service Usage Information, Geolocation Data |
| Email and communications providers | Enable us to send you emails and notifications | Contact Data, Communication Data |
| Cloud infrastructure and hosting providers | Store and process data on our behalf | All categories as necessary |
| Identity verification providers | Verify the identity of Brands and Creators | Contact Data, Account Data |
| Customer support platforms | Enable us to respond to your enquiries and support requests | Contact Data, Communication Data, Feedback and Support Information |
| Marketing and advertising partners | Help us deliver advertising and communications about our Services | Contact Data, Device and Network Information, Service Usage Information |
| Legal and professional advisors | Advise us on legal and compliance matters | Data relevant to the matter concerned |
| Regulatory and law enforcement bodies | Where required by applicable law | Data relevant to the request or obligation |
Table F – Cookie Categories
The following table describes the categories of cookies and similar tracking technologies used on our platform.
| Category | Purpose | Examples | Consent required? |
|---|---|---|---|
| Strictly necessary | Essential for the platform to function — authentication, security, session management, and load balancing. These cookies cannot be disabled without breaking core functionality. | Session tokens, CSRF protection cookies, load-balancer cookies | No — these are exempt from consent requirements under UK PECR |
| Performance / analytics | Collect anonymous information about how visitors use the site — which pages are visited, how long users spend on each page, and any errors encountered. Help us understand usage patterns and improve the platform. | Google Analytics (_ga, _gid, _gat) | Yes |
| Functionality | Remember choices you make — language preference, region, notification settings — to provide a more personalised and consistent experience across visits. | Language and region preference cookies | Yes |
| Targeting / advertising | Used to deliver advertising relevant to your interests, limit how often you see a particular ad, and measure the effectiveness of advertising campaigns. Set by us and by trusted third-party advertising partners. | Ad network and retargeting cookies | Yes |