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interlike.app
Privacy Policy
Updated November 20, 2020
Interlike takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.
We recommend that you read this privacy policy in full to ensure you are fully informed. However, to make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections that are specifically applicable to Clients (Section 2), Users (Section 3), and Visitors (Section 4). Sections 1 and 5 are applicable to everyone.
If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 5.
To the extent we provide you with notice of different or additional privacy policies, those policies will govern such interactions.
1. The Basics
A. About Us
Interlike is an online photo marketing platform (the "App") operated by Interlike New Zealand Ltd, a company headquartered in Tokoroa in New Zealand ("we," "us," "our," and "Interlike"). The App is offered through our websites, including Upload App www.web.interlike.app, Dashboard www.my.interlikeapp.com and any other website or mobile application owned, operated or controlled by us (we'll collectively refer to these as the "Interlike Site," and together with the App, the "Service").
Our Service enables our Clients to, among other things, set up photo marketing campaigns via the App to apply branding to User uploaded images, send the resulting images via email and sms, collect User data, and display User images on Campaign Websites and Online Galleries. We also provide other related services, such as generating post campaign insights to help our Clients track and report on the success of their photo marketing campaigns. Find out more about our App and related services here.
B. Key Terms Definitions
In this privacy policy, these terms have the following meanings:
"Affiliate" means an entity that directly or indirectly Controls, is Controlled by or is under common Control with an entity.
"User" is a person a Client may engage with through our App. In other words, a User is any individual who uploaded their photo via the App, or otherwise features in content created, using the App. For example, if you are a Client, a customer visiting your Campaign site who uploads their photo and submits their details to be featured in a Campaign Gallery would be considered a User.
"Control" means an ownership, voting or similar interest representing fifty percent (50%) or more of the total interests then outstanding of the entity in question. The term "Controlled" shall be construed accordingly.
"Client" means any person or entity that has purchased our Service including the App and related services.
"Mobile App(s)" means any one or all of the Interlike applications available for Clients and Users to use on their mobile devices.
"Personal Information" means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
"Visitor" means, depending on the context, any person who visits any of our Interlike Sites, offices, or otherwise engages with us at our events or in connection with our marketing or recruitment activities.
"you" and "your" means, depending on the context, either a Client, a User, or a Visitor.
2. Privacy for Clients
This section applies to the Personal Information we collect and process from a Client or potential Client through the provision of the Service. If you are not a Client, the Visitors or Users section of this policy may be more applicable to you and your data. In this section, "you" and "your" refer to Clients and potential Clients.
A. Information We Collect
The Personal Information that we collect depends on the context of your interactions with Interlike, your Interlike dashboard settings, the products and features you use, your location, and applicable law. However, the Personal Information we collect broadly falls into the following categories:
(i) Information you provide to us: You (or your organization) may provide certain Personal Information to us when you purchase Interlike Service, get allocated an Interlike dashboard account and use the Service, consult with our customer service team, send us an email or communicate with us in any other way.
This information may include:
Service Usage Data may include:
Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other Personal Information we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and service.
B. Use of Personal Information
We may use the Personal Information we collect or receive through the Service (alone or in combination with other data we source) for the purposes and on the legal bases identified below:
We and our third-party partners may use various technologies to collect and store Service Usage Data when you use our Service (as discussed above), and this may include using cookies and similar tracking technologies, such as pixels, web beacons, and if you use our Mobile Apps, through our SDKs deployed on your mobile device. For example, we use web beacons in the emails we send on your behalf, which enable us to track certain behavior, such as whether the email sent through the Service was delivered and opened and whether links within the email were clicked. Both web beacons and SDKs allow us to collect information such as the recipient's IP address, browser, email client type and other similar data as further described above details. We use this information to measure the performance of your campaigns, to provide analytics information, enhance the effectiveness of our Service, and for other purposes described above. Reports are also available to us, so we may collect and review that information.
D. User Contact Information
In order to deliver Users their photos processed via the App, the User submits their contact information, such as their names and email addresses. We use and process this information to provide the Service in accordance with our contract with you or your organization and this privacy policy.
User Contact Information is stored in a List unique for each of your campaigns. We do not, under any circumstances, sell this User Contact Information. Users are able to unsubscribe directly from the List via a link in the email sent to them with their photo. If someone Unsubscribes, the User Contact Information is immediately deleted from all of Interlike Sites. You may request an export of User Contact Information from Interlike. It will be available in a .csv file.
F. Your Data Protection Rights
Depending on the country in which you reside, you may have the following data protection rights:
3. Privacy for Users
This section applies to the information we process about our Clients' Users as a data controller. Our Service is intended for use by our Clients. As a result, for much of the Personal Information we collect and process about Users through the Service, we act as a processor on behalf of our Clients. Interlike is not responsible for the privacy or security practices of our Clients, which may differ from those set forth in this privacy policy. Please check with individual Clients about the policies they have in place. For purposes of this section, "you" and "your" refer to Users.
A. Information We Collect
The Personal Information that we may collect or receive about you broadly falls into the following categories:
(i) Information we receive about you after you directly enter it into the App. In order to receive your photo or participate in a competition, you might elect to enter your personal details directly into the App. Depending on the set up of a particular campaign to participate in a promotion set up by the Client, you might be required to provide certain contact information or other Personal Information about you such as your name, email address, address, or telephone number. You will be able to opt in to receive further marketing communication from the Client, however this is optional and you will also have the opportunity to unsubscribe directly via a link in the email you receive as part of using the Service.
(ii) Photos we receive from you uploaded directly via the App and processed Client's specific branding. In order to participate in the Client's promotion, you will be required to upload your personal photo. You will be required to agree for your photo to be displayed on Client's Campaign Website which can be available to the public online and displayed on screens in public places. If you no longer wish for your photo to be used by the Client, you can request for it to be deleted by replying directly to an email that delivered your photo.
(iii) Information we collect automatically: When you interact with a Campaign site, Campaign App or an email that you receive from a Client as part of the Service, we may collect information about your device and interaction with an email. We use cookies and other tracking technologies to collect some of this information.
B. Use of Personal Information
We may use the Personal Information we collect or receive about you in reliance on our (and where applicable, our Clients') legitimate interests for the following purposes:
We and our third-party partners may use various technologies to automatically collect and store certain device and usage information (as discussed above) when you interact with a Client's Campaign Website, and this may include using cookies and similar tracking technologies, such as pixels and web beacons or if a Client is using our Mobile App, we may collect this information through our SDKs deployed on our Clients mobile device. For example, we use web beacons in the emails we send on behalf of our Clients. When you receive and engage with an email delivering your photo, web beacons track certain behavior such as whether the email sent through the Interlike platform was delivered and opened and whether links within the email were clicked. Both web beacons and SDKs allow us to collect information such as your IP address, browser, email client type, and other similar data as further described above. We use this information to measure the performance of our Clients' email campaigns, and to provide analytics information and enhance the effectiveness of our Service, and for the other purposes described above.
D. Your Data Protection Rights
Depending on the country in which you reside, you may have the following data protection rights:
As described above, for much of the Personal Information we collect and process about Users through the Service, we act as a processor on behalf of our Clients. In such cases, if you are a User and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by Interlike as a processor on behalf of our individual Clients, you should contact the relevant Client that is using the Interlike Service, and refer to their separate privacy policies.
If you no longer want to be contacted by one of our Clients through our Service, please unsubscribe directly from the link in the email that delivered your photo. If you contact us directly, we may either forward your request to the relevant Client or provide you with the identity of the Client to enable you to contact them directly.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
4. Privacy for Visitors
This section applies to Personal Information that we collect and process when you visit the Interlike Sites, and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities or when you visit our offices. In this section, "you" and "your" refer to Visitors.
A. Information We Collect
(i) Information you provide to us on the Interlike Sites or otherwise: Our Interlike Sites offer various ways to contact us, such as through form submissions, email or phone, to inquire about our company and Service. For example, we may ask you to provide certain Personal Information when you express an interest in obtaining information about us or our Service, take part in surveys, subscribe to marketing, apply for a role with Interlike, or otherwise contact us. We may also collect Personal Information from you in person when you attend our events or trade shows, if you visit our offices (where you will be required to register as a visitor and provide us with certain information that may also be shared with our service providers) or via a phone call with one of our sales representatives. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we may keep copies of any such communications for our records.
The Personal Information we collect may include:
The information we collect automatically includes:
We may use the information we collect through our Interlike Sites and in connection with our events and marketing activities (alone or in combination with other data we collect) for a range of reasons in reliance on our legitimate interests, including:
We use cookies and similar tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising.
E. Other Data Protection Rights
Depending on the country in which you reside, you may have the following data protection rights:
5. General Information
A. How We Share Information
We may share and disclose your Personal Information with the following types of third parties for the purposes described in this privacy policy (for purposes of this section, "you" and "your" refer to Clients, Users, and Visitors unless otherwise indicated).
(i) Our service providers: Sometimes, we share your information with our third-party service providers working on our behalf for the purposes described in this privacy policy. For example, companies we've hired to help us provide and support our Service or assist in protecting and securing our systems and services and other business-related functions.
Other examples include analyzing data, hosting data, engaging technical support for our Service, processing payments, and delivering content.
We use Mandrill by Mailchimp services in connection with our Service to deliver emails and provide other features. As such, you acknowledge and agree that by purchasing and using the Service, you are also bound by Mailchimp Privacy Policy.
In connection with our Service, we also use a third-party service provider, Twilio, Inc. We use Twilio's API, which allows us to build features into our Interlike application to enable us to deliver User's photos via sms. If you are a User, Twilio may need to collect and process certain Personal Information about you as a controller to provide such services. To learn more about Twilio's privacy practices, please visit https://www.twilio.com/legal/privacy
(ii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Interlike Site.
(v) Any other person with your consent.
B. Legal Basis for Processing Personal Information (EEA and UK Persons Only)
If you are located in the EEA or UK, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Our legitimate interests are described in more detail in this privacy policy in the sections above titled "Use of Personal Information", but they typically include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Service and our Interlike Sites; and supporting our marketing activities.
If you are a Client, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have your consent to do so.
If you have questions or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Questions and Concerns" section below.
C. Your Choices and Opt-Outs
Clients and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided in the "Questions and Concerns" section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Clients cannot opt out of these messages.
D. Our Security
We take appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at privacy@interlike.app.
Interlike dashboard accounts require a username and password to log in, which we will provide. Clients must keep their username and password secure, and never disclose it to a third party.
E. International Transfers
(i) All Data, including personal and non-personal information, that is entered into the Service by You, is transferred to Interlike's servers as a function of transmission across the Internet. By using the Service, You consent to Your personal information being transferred to our servers as set out in this Policy.
Currently our servers are located in the Federal Republic of Germany (Germany), and Your personal information will be routed through, and stored on, those servers as part of the Service. Interlike servers have certified that it adheres to relevant safe privacy principles. If the location of our servers changes in the future, we will update this Policy. You should review our Policy regularly to keep informed of any updates.
By providing Your personal information to Interlike, You consent to Interlike storing Your personal information on servers hosted in Germany. While Your personal information will be stored on servers located in Germany, it will remain within Interlike's effective control at all times. The server host's role is limited to providing a hosting and storage service to Interlike, and we've taken steps to ensure that our server hosts do not have access to, and use the necessary level of protection for, Your personal information.
If You do not want Your personal information to be transferred to a server located in Germany, You should not provide Interlike with Your personal information or use the Service.
With respect to Personal Information received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the regulatory enforcement powers of the New Zealand Privacy Commissioner Office. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Clients located in Switzerland, United Kingdom, and the EEA are subject to our Data Processing Addendum available here.
(iii) Clients, Users and Visitors located in Australia
If you are a Client, User or Visitor who accesses our Service in Australia, this section applies to you. We are subject to the operation of the Privacy Act 1988 ("Australian Privacy Act"). Here are the specific points you should be aware of:
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:
G. California Privacy
The California Consumer Privacy Act ("CCPA") provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which may include our Clients with whom you have a relationship) disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.
When offering services to its Clients, Interlike acts as a "service provider" under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our Clients in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA to the Client with whom you have a direct relationship.
Consistent with California law, if you choose to exercise your applicable CCPA rights, we won't charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.
H. Do not Track
Certain state laws require us to indicate whether we honor "Do Not Track" settings in your browser. Interlike adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.
I. Changes to this Policy
We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Interlike Sites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Interlike Site.
J. Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please contact by postal mail or email:
For EEA, Swiss and UK Residents:
For the purposes of EU data protection legislation, Interlike New Zealand Ltd is the controller of your Personal Information. Our Data Protection Officer can be contacted at privacy@interlike.app
For any other Residents:
Interlike New Zealand Ltd
Attn. Privacy Officer privacy@interlike.app
PO Box 46050
Herne Bay
Auckland 1147
New Zealand
Interlike takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.
We recommend that you read this privacy policy in full to ensure you are fully informed. However, to make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections that are specifically applicable to Clients (Section 2), Users (Section 3), and Visitors (Section 4). Sections 1 and 5 are applicable to everyone.
If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 5.
To the extent we provide you with notice of different or additional privacy policies, those policies will govern such interactions.
1. The Basics
A. About Us
Interlike is an online photo marketing platform (the "App") operated by Interlike New Zealand Ltd, a company headquartered in Tokoroa in New Zealand ("we," "us," "our," and "Interlike"). The App is offered through our websites, including Upload App www.web.interlike.app, Dashboard www.my.interlikeapp.com and any other website or mobile application owned, operated or controlled by us (we'll collectively refer to these as the "Interlike Site," and together with the App, the "Service").
Our Service enables our Clients to, among other things, set up photo marketing campaigns via the App to apply branding to User uploaded images, send the resulting images via email and sms, collect User data, and display User images on Campaign Websites and Online Galleries. We also provide other related services, such as generating post campaign insights to help our Clients track and report on the success of their photo marketing campaigns. Find out more about our App and related services here.
B. Key Terms Definitions
In this privacy policy, these terms have the following meanings:
"Affiliate" means an entity that directly or indirectly Controls, is Controlled by or is under common Control with an entity.
"User" is a person a Client may engage with through our App. In other words, a User is any individual who uploaded their photo via the App, or otherwise features in content created, using the App. For example, if you are a Client, a customer visiting your Campaign site who uploads their photo and submits their details to be featured in a Campaign Gallery would be considered a User.
"Control" means an ownership, voting or similar interest representing fifty percent (50%) or more of the total interests then outstanding of the entity in question. The term "Controlled" shall be construed accordingly.
"Client" means any person or entity that has purchased our Service including the App and related services.
"Mobile App(s)" means any one or all of the Interlike applications available for Clients and Users to use on their mobile devices.
"Personal Information" means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
"Visitor" means, depending on the context, any person who visits any of our Interlike Sites, offices, or otherwise engages with us at our events or in connection with our marketing or recruitment activities.
"you" and "your" means, depending on the context, either a Client, a User, or a Visitor.
2. Privacy for Clients
This section applies to the Personal Information we collect and process from a Client or potential Client through the provision of the Service. If you are not a Client, the Visitors or Users section of this policy may be more applicable to you and your data. In this section, "you" and "your" refer to Clients and potential Clients.
A. Information We Collect
The Personal Information that we collect depends on the context of your interactions with Interlike, your Interlike dashboard settings, the products and features you use, your location, and applicable law. However, the Personal Information we collect broadly falls into the following categories:
(i) Information you provide to us: You (or your organization) may provide certain Personal Information to us when you purchase Interlike Service, get allocated an Interlike dashboard account and use the Service, consult with our customer service team, send us an email or communicate with us in any other way.
This information may include:
- Business contact information (such as your name, job title, organization, location, phone number, email address, and country);
- Marketing information (such as your contact preferences);
- Troubleshooting and support data (which is data you provide or we otherwise collect in connection with support queries we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help inquiry); and
- Payment information (including your credit card numbers and associated identifiers and billing address).
Service Usage Data may include:
- Device information: We collect information about the device and applications you use to access the Service, such as your IP address, your operating system, your browser ID, and other information about your system and connection. If you are using our Mobile App, we may also collect information about the cellular network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's name and unique device ID, and information about the features of our Mobile App that you accessed.
- Log data: Our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP addresses and your activity in the Service (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take (for example, which features you used)), device event information (such as system activity, error reports (sometimes called 'crash dumps')), and hardware settings. We may also access metadata and other information associated with files that you upload into our Service.
- Usage data: We collect usage data about you whenever you interact with our Service, which may include the dates and times you access the Service and your browsing activities (such as what portions of the Service you used). We also collect information regarding the performance of the Service, including metrics related to the deliverability of emails and other communications you send through the Service. If you are using our Mobile App, we may collect information about how often you use the Mobile App and other performance data. This information allows us to improve the content and operation of the Service, and facilitate research and analysis of the Service.
Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other Personal Information we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and service.
B. Use of Personal Information
We may use the Personal Information we collect or receive through the Service (alone or in combination with other data we source) for the purposes and on the legal bases identified below:
- To bill and collect money owed to us by you to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in accordance with our legitimate interests to operate and administer our Service. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see the "Our Security" section of this privacy policy.
- To send you system alert messages in reliance on our legitimate interests in administering the Service and providing certain features. For example, we may inform you about temporary or permanent changes to our Service, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, and changes to this privacy policy.
- To communicate with you about your Campaigns and provide customer support to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our Service.
- To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements in reliance on our legitimate interests.
- To prosecute and defend a court, arbitration, or similar legal proceeding.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- To provide, support and improve the Service to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Service and providing certain features. For example, this may include sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to you. When we share your Personal Information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws. For further information about how we share your information, refer to Section 5 below.
We and our third-party partners may use various technologies to collect and store Service Usage Data when you use our Service (as discussed above), and this may include using cookies and similar tracking technologies, such as pixels, web beacons, and if you use our Mobile Apps, through our SDKs deployed on your mobile device. For example, we use web beacons in the emails we send on your behalf, which enable us to track certain behavior, such as whether the email sent through the Service was delivered and opened and whether links within the email were clicked. Both web beacons and SDKs allow us to collect information such as the recipient's IP address, browser, email client type and other similar data as further described above details. We use this information to measure the performance of your campaigns, to provide analytics information, enhance the effectiveness of our Service, and for other purposes described above. Reports are also available to us, so we may collect and review that information.
D. User Contact Information
In order to deliver Users their photos processed via the App, the User submits their contact information, such as their names and email addresses. We use and process this information to provide the Service in accordance with our contract with you or your organization and this privacy policy.
User Contact Information is stored in a List unique for each of your campaigns. We do not, under any circumstances, sell this User Contact Information. Users are able to unsubscribe directly from the List via a link in the email sent to them with their photo. If someone Unsubscribes, the User Contact Information is immediately deleted from all of Interlike Sites. You may request an export of User Contact Information from Interlike. It will be available in a .csv file.
F. Your Data Protection Rights
Depending on the country in which you reside, you may have the following data protection rights:
- To access; correct; update; port; delete; restrict or object to our processing of your Personal Information. You can exercise these rights by visiting by emailing personaldatarequests@interlike.app.
- The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA and UK are available here, Switzerland are available here, Australian are available here.
- Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
3. Privacy for Users
This section applies to the information we process about our Clients' Users as a data controller. Our Service is intended for use by our Clients. As a result, for much of the Personal Information we collect and process about Users through the Service, we act as a processor on behalf of our Clients. Interlike is not responsible for the privacy or security practices of our Clients, which may differ from those set forth in this privacy policy. Please check with individual Clients about the policies they have in place. For purposes of this section, "you" and "your" refer to Users.
A. Information We Collect
The Personal Information that we may collect or receive about you broadly falls into the following categories:
(i) Information we receive about you after you directly enter it into the App. In order to receive your photo or participate in a competition, you might elect to enter your personal details directly into the App. Depending on the set up of a particular campaign to participate in a promotion set up by the Client, you might be required to provide certain contact information or other Personal Information about you such as your name, email address, address, or telephone number. You will be able to opt in to receive further marketing communication from the Client, however this is optional and you will also have the opportunity to unsubscribe directly via a link in the email you receive as part of using the Service.
(ii) Photos we receive from you uploaded directly via the App and processed Client's specific branding. In order to participate in the Client's promotion, you will be required to upload your personal photo. You will be required to agree for your photo to be displayed on Client's Campaign Website which can be available to the public online and displayed on screens in public places. If you no longer wish for your photo to be used by the Client, you can request for it to be deleted by replying directly to an email that delivered your photo.
(iii) Information we collect automatically: When you interact with a Campaign site, Campaign App or an email that you receive from a Client as part of the Service, we may collect information about your device and interaction with an email. We use cookies and other tracking technologies to collect some of this information.
- Device information: We collect information about the device and applications you use to access emails sent through our Service, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
- Usage data: It is important for us to ensure the security and reliability of the Service we provide. Therefore, we also collect usage data about your interactions with campaigns (and/or emails) sent through the Service, which may include dates and times you access campaigns (and/or emails) and your browsing activities (such as what pages are viewed and which emails are opened). We also collect information regarding the performance of the Service, including metrics related to the deliverability of emails and other electronic communications that our Clients send through the Service. This information allows us to improve the content and operation of the Service and facilitate research and perform analysis into the use and performance of the Service.
B. Use of Personal Information
We may use the Personal Information we collect or receive about you in reliance on our (and where applicable, our Clients') legitimate interests for the following purposes:
- To protect the rights and safety of Clients, Users, third parties, or Interlike, we review the photos submitted by the Users to make sure they comply with the law. We, or our third-party service provider, may review personal details associated with questionable images, which may include your contact information.
- To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
- To prosecute and defend a court, arbitration, or similar legal proceeding.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- To provide, support and improve the Service. For example, this may include sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to our Clients. When we share Personal Information with third parties, we take steps to protect your information in a manner that is consistent with applicable privacy laws. For further information about how we share information, refer to Section 5 below.
- To carry out other business purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.
We and our third-party partners may use various technologies to automatically collect and store certain device and usage information (as discussed above) when you interact with a Client's Campaign Website, and this may include using cookies and similar tracking technologies, such as pixels and web beacons or if a Client is using our Mobile App, we may collect this information through our SDKs deployed on our Clients mobile device. For example, we use web beacons in the emails we send on behalf of our Clients. When you receive and engage with an email delivering your photo, web beacons track certain behavior such as whether the email sent through the Interlike platform was delivered and opened and whether links within the email were clicked. Both web beacons and SDKs allow us to collect information such as your IP address, browser, email client type, and other similar data as further described above. We use this information to measure the performance of our Clients' email campaigns, and to provide analytics information and enhance the effectiveness of our Service, and for the other purposes described above.
D. Your Data Protection Rights
Depending on the country in which you reside, you may have the following data protection rights:
- To access; correct; update; port; delete; restrict or object to our processing of your Personal Information. You can exercise these rights by visiting by emailing personaldatarequests@interlike.app.
- You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA and UK are available here, Switzerland are available here, Australian are available here.
As described above, for much of the Personal Information we collect and process about Users through the Service, we act as a processor on behalf of our Clients. In such cases, if you are a User and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by Interlike as a processor on behalf of our individual Clients, you should contact the relevant Client that is using the Interlike Service, and refer to their separate privacy policies.
If you no longer want to be contacted by one of our Clients through our Service, please unsubscribe directly from the link in the email that delivered your photo. If you contact us directly, we may either forward your request to the relevant Client or provide you with the identity of the Client to enable you to contact them directly.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
4. Privacy for Visitors
This section applies to Personal Information that we collect and process when you visit the Interlike Sites, and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities or when you visit our offices. In this section, "you" and "your" refer to Visitors.
A. Information We Collect
(i) Information you provide to us on the Interlike Sites or otherwise: Our Interlike Sites offer various ways to contact us, such as through form submissions, email or phone, to inquire about our company and Service. For example, we may ask you to provide certain Personal Information when you express an interest in obtaining information about us or our Service, take part in surveys, subscribe to marketing, apply for a role with Interlike, or otherwise contact us. We may also collect Personal Information from you in person when you attend our events or trade shows, if you visit our offices (where you will be required to register as a visitor and provide us with certain information that may also be shared with our service providers) or via a phone call with one of our sales representatives. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we may keep copies of any such communications for our records.
The Personal Information we collect may include:
- Business contact information (such as your name, phone number, email address and country);
- Professional information (such as your job title, institution or company);
- Nature of your communication;
- Marketing information (such as your contact preferences); and
- Any information you choose to provide to us when completing any 'free text' boxes in our forms.
The information we collect automatically includes:
- Device information: such as your IP address, your browser, device information, unique device identifiers, mobile network information, request information (speed, frequency, the site from which you linked to us ("referring page"), the name of the website you choose to visit immediately after ours (called "exit page"), information about other websites you have recently visited and the web browser you used (software used to browse the internet) including its type and language)
- Usage data: such as information about how you interact with our emails, Interlike Sites, and other websites (such as the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage).
We may use the information we collect through our Interlike Sites and in connection with our events and marketing activities (alone or in combination with other data we collect) for a range of reasons in reliance on our legitimate interests, including:
- To provide, operate, optimize, and maintain the Interlike Sites.
- To send you marketing information, product recommendations and non-transactional communications (e.g., email, telemarketing calls, SMS, or push notifications) about us, in accordance with your marketing preferences, including information about our products, services, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent.
- For recruitment purposes if you have applied for a role with Interlike.
- To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
- To manage the Interlike Sites and system administration and security.
- To manage event registrations and attendance, including sending related communications to you.
- To register visitors to our offices for security reasons and to manage non-disclosure agreements that visitors may be required to sign.
- To improve the navigation and content of the Interlike Sites.
- To identify any server problems or other IT or network issues.
- To process transactions and to set up online accounts.
- To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
- To help us provide, improve and personalize our marketing activities.
- To facilitate the security and continued proper functioning of the Interlike Sites.
- To carry out research and development to improve our Interlike Sites, products and services.
- To conduct marketing research, advertise to you, provide personalized information about us on and off our Interlike Sites, and to provide other personalized content based on your activities and interests to the extent necessary for our legitimate interests in supporting our marketing activities or advertising our Service or instances where we seek your consent.
- To carry out other legitimate business purposes, as well as other lawful purposes, such as data analysis, fraud monitoring and prevention, identifying usage trends and expanding our business activities in reliance on our legitimate interests.
- To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our Interlike Sites and Service, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, or responding to lawful requests.
- Social media platforms and widgets. The Interlike Sites include social media features, such as the Facebook Share button. These features may collect information about your IP address and which page you are visiting on our Interlike Site, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Interlike Site. We also maintain presences on social media platforms, including Facebook, Twitter, Youtube, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
- Links to third-party websites. The Interlike Sites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
- Contests and sweepstakes. We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on the Interlike Sites or through social media (collectively, "Promotions"). Participation in our Promotions is completely voluntary. Information requested for entry may include Personal Information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer our Promotions. We may also, unless prohibited by the Promotion's rules or law, use the information provided to communicate with you, or other people you select, about our Service. We may share this information with our affiliates and other organizations or service providers in line with this privacy policy and the rules posted for our Promotions.
We use cookies and similar tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising.
E. Other Data Protection Rights
Depending on the country in which you reside, you may have the following data protection rights:
- To access; correct; update; port; delete; restrict or object to our processing of your Personal Information. You can exercise these rights by visiting by emailing personaldatarequests@interlike.app.
- You may also have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA and UK are available here, Switzerland are available here, Australian are available here.
- Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. You can also contact us at any time to update your marketing preferences (see Section 5. General Information, C. Your Choices and Opt-Outs below).
5. General Information
A. How We Share Information
We may share and disclose your Personal Information with the following types of third parties for the purposes described in this privacy policy (for purposes of this section, "you" and "your" refer to Clients, Users, and Visitors unless otherwise indicated).
(i) Our service providers: Sometimes, we share your information with our third-party service providers working on our behalf for the purposes described in this privacy policy. For example, companies we've hired to help us provide and support our Service or assist in protecting and securing our systems and services and other business-related functions.
Other examples include analyzing data, hosting data, engaging technical support for our Service, processing payments, and delivering content.
We use Mandrill by Mailchimp services in connection with our Service to deliver emails and provide other features. As such, you acknowledge and agree that by purchasing and using the Service, you are also bound by Mailchimp Privacy Policy.
In connection with our Service, we also use a third-party service provider, Twilio, Inc. We use Twilio's API, which allows us to build features into our Interlike application to enable us to deliver User's photos via sms. If you are a User, Twilio may need to collect and process certain Personal Information about you as a controller to provide such services. To learn more about Twilio's privacy practices, please visit https://www.twilio.com/legal/privacy
(ii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Interlike Site.
(v) Any other person with your consent.
B. Legal Basis for Processing Personal Information (EEA and UK Persons Only)
If you are located in the EEA or UK, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Our legitimate interests are described in more detail in this privacy policy in the sections above titled "Use of Personal Information", but they typically include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Service and our Interlike Sites; and supporting our marketing activities.
If you are a Client, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have your consent to do so.
If you have questions or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Questions and Concerns" section below.
C. Your Choices and Opt-Outs
Clients and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided in the "Questions and Concerns" section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Clients cannot opt out of these messages.
D. Our Security
We take appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at privacy@interlike.app.
Interlike dashboard accounts require a username and password to log in, which we will provide. Clients must keep their username and password secure, and never disclose it to a third party.
E. International Transfers
(i) All Data, including personal and non-personal information, that is entered into the Service by You, is transferred to Interlike's servers as a function of transmission across the Internet. By using the Service, You consent to Your personal information being transferred to our servers as set out in this Policy.
Currently our servers are located in the Federal Republic of Germany (Germany), and Your personal information will be routed through, and stored on, those servers as part of the Service. Interlike servers have certified that it adheres to relevant safe privacy principles. If the location of our servers changes in the future, we will update this Policy. You should review our Policy regularly to keep informed of any updates.
By providing Your personal information to Interlike, You consent to Interlike storing Your personal information on servers hosted in Germany. While Your personal information will be stored on servers located in Germany, it will remain within Interlike's effective control at all times. The server host's role is limited to providing a hosting and storage service to Interlike, and we've taken steps to ensure that our server hosts do not have access to, and use the necessary level of protection for, Your personal information.
If You do not want Your personal information to be transferred to a server located in Germany, You should not provide Interlike with Your personal information or use the Service.
With respect to Personal Information received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the regulatory enforcement powers of the New Zealand Privacy Commissioner Office. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Clients located in Switzerland, United Kingdom, and the EEA are subject to our Data Processing Addendum available here.
(iii) Clients, Users and Visitors located in Australia
If you are a Client, User or Visitor who accesses our Service in Australia, this section applies to you. We are subject to the operation of the Privacy Act 1988 ("Australian Privacy Act"). Here are the specific points you should be aware of:
- Please note that if you do not provide us with your Personal Information or if you withdraw your consent for us to collect, use and disclose your Personal Information, we may be unable to provide the Service to you.
- Where we collect Personal Information of our Visitors, the Personal Information we ask you to provide will be information that is reasonably necessary for, or directly related to, one or more of our functions or activities. Please see Section 4, of this privacy policy for examples of the types of Personal Information we may ask Visitors to provide.
- Where we say we assume an obligation about Personal Information, we will also require our contractors and subcontractors to undertake a similar obligation.
- We will not use or disclose Personal Information for the purpose of our direct marketing to you unless:
- you have consented to receive direct marketing;
- you would reasonably expect us to use your personal details for marketing; or
- we believe you may be interested in the material but it is impractical for us to obtain your consent.
- you have consented to receive direct marketing;
- Our servers are located in Germany. In addition, we or our subcontractors may use cloud technology to store or process Personal Information, which may result in storage of data outside Australia. It is not practicable for us to specify in advance which country will have jurisdiction over this type of offshore activity. All of our subcontractors, however, are required to comply with the Australian Privacy Act in relation to the transfer or storage of Personal Information overseas.
- We may also share your Personal Information outside of Australia to our business operations in other countries. While it is not practicable for us to specify in advance each country where your Personal Information may be disclosed, typically we may disclose your Personal Information to New Zealand, the United States, Canada and the European Union.
- You may access the Personal Information we hold about you. If you wish to access your Personal Information, you may do so by emailing us at personaldatarequests@interlike.app. We will respond to all requests for access within a reasonable time.
- If you are unsatisfied with our response to a privacy matter, you may consult either an independent advisor or contact the Office of the Australian Information Commissioner for additional help. We will provide our full cooperation if you pursue this course of action.
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:
- Whether we have a legal or contractual need to retain the data.
- Whether the data is necessary to provide our Service.
- Whether our Clients have the ability to access and delete the data within their Interlike dashboard accounts.
G. California Privacy
The California Consumer Privacy Act ("CCPA") provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which may include our Clients with whom you have a relationship) disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.
When offering services to its Clients, Interlike acts as a "service provider" under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our Clients in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA to the Client with whom you have a direct relationship.
Consistent with California law, if you choose to exercise your applicable CCPA rights, we won't charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.
H. Do not Track
Certain state laws require us to indicate whether we honor "Do Not Track" settings in your browser. Interlike adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.
I. Changes to this Policy
We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Interlike Sites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Interlike Site.
J. Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please contact by postal mail or email:
For EEA, Swiss and UK Residents:
For the purposes of EU data protection legislation, Interlike New Zealand Ltd is the controller of your Personal Information. Our Data Protection Officer can be contacted at privacy@interlike.app
For any other Residents:
Interlike New Zealand Ltd
Attn. Privacy Officer privacy@interlike.app
PO Box 46050
Herne Bay
Auckland 1147
New Zealand