Privacy policy

Introduction

This Privacy Policy describes how Clipsource (we, us or our), corp. reg. no. 556764-3019, at the address Tegnérgatan 28, 113 59, Stockholm handles a User’s personal data. The Privacy Policy clarifies what kind of personal data about a User we collect when they visit our website or when using our services, how it is processed, as well as a Users’ rights as a data subject.

At Clipsource the privacy and security of our Users are of paramount importance. Clipsource is committed to protecting the data you share with us. This privacy policy explains how Clipsource processes information that can be used to directly or indirectly identify an individual collected through the use of our services and when visiting our website. Personal user data may also be collected from third-party Sources, i. e. Customers who add user information to the service.

For the purposes of this policy, Clipsource defines the term “User” and “Data subject” as anyone using the services or website as a private individual or as representative of a company, the term “Personal data” as a users personal information and the term “Sources” or “Customers” as those who use our services to upload, collect and process personal data (“Users”). We define the term Website as our corporate site. We define the term Service as anything powered by Clipsource (such as a Pressroom website or the video portal; https://media.clipsource.com/list/latest). 

We trust that this Privacy Policy answers your questions about our collection, use, protection and disclosure of your personal data. If you have additional questions, please contact us at support@clipsource.com

2. Clipsource and our Customers 

In this section we will explain the relationship that we have with our Customers when it comes to processing data. 

2.1 Clipsource’s (Service) role as a data processor

When providing software and services to a company, Clipsource is acting as a data processor for the personal data we process and store as part of providing the services. As a data processor, we will only process personal data in accordance with a Customer’s permission and instructions — for example, as set out in an agreement with us.

In some cases we, Clipsource, may act as Data Controllers, as we have defined the purpose of the processing of personal data. For example, when personal data is used for sending information from the Clipsource corporate media center and managing Users that have signed up to access the Clipsource media portal, e.g. media.clipsource.com.

2.2 Sources (Customers) role as a data controller

The data controller (Source) is responsible for the personal data processed and stored. A controller is responsible for individuals who engage with their individual brands detailing how they collect and use information, for what purposes and how they obtain consents (when applicable). If data subjects want to know what data is maintained about them or decide they want to discontinue their relationship with the Source, it is the data controller’s responsibility to adhere to those requests.

Clipsource is a natural part of the Customer’s duties as data controller, in the sense that Clipsource services constitute parts of the processing of personal data that the Source must ensure are compliant with applicable privacy legislation. Thus, when Clipsource processes personal data on behalf of its customers, we must do so in accordance with privacy legislation applicable for data processors.

3. Processing personal data

Here you can read about what personal data we process and why, how it is collected, involved processing activities, who we share the data with, including information about the transfer of personal data outside the EU / EEA, and how long we store your personal data.

3.1 Purpose of processing personal data

3.1.1 Providing our services 

We process personal information in order to provide our services and to facilitate and enable Sources who use our services to collect User information in order to manage and distribute press information and other content.

3.1.2 Improve our services

We process personal information to improve our website and services and make them more user-friendly. This includes, for example, producing statistics and analyzing how our services are used. We also use personal data based on activities, for example, messages sent by our Sources and messages sent to support or feedback sent to us through features created for that purpose. To the extent possible, we use your personal information in an aggregated or anonymized form in this treatment.

3.1.3 Marketing

We also process personal information to contact you for direct marketing purposes or to email you with information we think you might find valuable. Marketing communication will only be sent if you have given us permission to do so, either through form submission on our website or another agreed way. You can unsubscribe from further marketing messages at any time by using the link at the bottom of each email that says ‘Unsubscribe’. These marketing efforts apply specifically to Users who have visited our corporate site. We will not target Users that our customers have added. Customers are responsible for how they manage/target their contacts.

3.2 How is personal data collected and processed?

Below you can read how we, Clipsource, and our customers collect your personal data. Personal data in any manner that is incompatible with the purposes for which they were collected.

3.2.1 Customer import lists

Customers may collect personal information by adding individual Users or by importing User lists. Upon adding Users, Customers can create their own distribution lists for different types of content and messages. They can also use functions to analyze how Users interact with and respond to their content and messages. 

3.2.2 Registering for an account or providing us with your personal information

We collect personal information when a user chooses to sign up, register and add personal data to their account or provides us with their personal information via, form fill or another voluntary method. By doing so they accept our terms and conditions. 

3.2.3 Based on your activity

We also collect personal information based on your website activity and activity in emails we send to you, including how you use our website, as well as from third party sources. More information about our collection of personal data using cookies can be found in our cookie policy.

3.3 What personal data is processed?

Personal data collected and processed is;

• Name and contact details such as name, email address and telephone number.

• Language preference and country

• Company name

• Information published on publicly accessible sources, such as social media and other media channels online, for example, Twitter, Facebook or other platforms; and Information about interaction with emails sent to a User.

• Data you write in a contact form

• Navigation information: Information about your computer, device, visits to our website, which website you came from and which link you clicked or campaign you clicked on to visit our website. If you opt in to use our cookies, we also track your IP address, geographical location, page visits and page views.

3.4 Retention and deletion

We will only store your personal data for as long as is necessary for the purpose for which it was collected, and to fulfil our legal obligations to store data in other ways, but no longer than applicable law allows.

Clipsource provides the tools to allow Customers to not retain data longer than is necessary and to fulfil the purposes for which it was collected. When a Users’ account is deleted, all personal data collected through the service will be deleted, as required by applicable law.

Users registered to our services can at any time access and edit, update or delete their personal information by logging in with their username and password to the Clipsource service and any press room powered by the Clipsource service. Users have the right to extract their personal data in a structured, widely used and machine-readable format for the purpose of transferring data (so-called data portability).

Users can by their own choice choose how they receive information. Users can at any time unsubscribe from messages. It’s either done directly through a link in the email or by contacting the sender of the message.

Users that have not registered an account or those who no longer wish to receive messages from Clipsource or from a Customer using Clipsource services can at any point of receiving a message sent, choose to unsubscribe. By unsubscribing from a Customer’s distribution list, all stored personal information of the User will be removed.

3.5 Transfer of personal data outside the EU/EEA

Clipsource uses subcontractors to process personal data and may export our Customer’s data outside the EU/EEA in this regard. These subcontractors are typically vendors of cloud services or other IT hosting services. When using subcontractors, Clipsource will enter into a data processing agreement (DPA) with subcontractors in order to safeguard your privacy rights and to fulfil our obligations towards our Customers. When subcontractors are located outside the EU, Clipsource ensures legal grounds for such international transfers on behalf of you or our Customers, for example by ensuring that the country in which the recipient is located ensures an adequate level of data protection according to the European Commission or by use of standard contractual clauses that the European Commission has issued ensuring suitable measures to safeguard your rights and freedoms.

On 16 July 2020, the Court of Justice of the European Union (CJEU) issued a ruling regarding the transfer of personal data of EU individuals outside the EEA (Schrems II). In Schrems II, the CJEU ruled that the EU-US Privacy Shield was no longer a valid mechanism to transfer personal data from the EEA to the US. However, in the same ruling, the CJEU confirmed that companies can (subject to implementing supplementary measures, if required) continue to use Standard Contractual Clauses as a valid mechanism for transferring personal data outside of the EEA.

The Schrems II ruling validated the use of Standard Contractual Clauses (SCCs) as a mechanism for transferring customer data outside the EEA and our customers can continue to rely on the SCCs for any transfer of customer data outside the EEA in compliance with GDPR.

The SCCs are a pre-approved data transfer mechanism under GDPR, applicable in all EU Member States, which enable the lawful transfer of personal data to third countries (countries outside of the European Economic Area that haven't received an adequacy decision from the European Commission).

4. Security measures

We have taken a number of security measures to ensure that the personal data we save is secure. We maintain appropriate safeguards and safety standards to protect personal data against unauthorized access, enlightenment or abuse. We also monitor our systems to detect vulnerabilities to protect personal data. 

5. Users rights

We are responsible for, and act as data controllers insofar as our capacity as a service provider of features from our services that allows for sharing contacts to enable certain processing activities (subject to our terms and conditions), but otherwise, we only act as a data processor on behalf of our Customers (Sources) with regard to their processing of personal data using the same features. You can exercise your rights in relation to the processing of personal data whether your right concerns the processing of our Customers or Clipsource’s processing. 

5.1 Right of access and rectification

Users have the right to access information regarding what personal data is processed and to access and rectify such personal data.

5.2 Right to erasure

Users have the right to have their data ‘erased’ without undue delay in the following circumstances:

The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed

Users withdraw consent on which the processing is based (if applicable) and there is no other legal ground for the processing

you object to the processing of personal data and Clipsource or our Customers do not have any overriding legitimate grounds for the processing

The processed personal data is unlawfully processed, or the processed personal data has to be erased for compliance with legal obligations.

5.3 Right to restriction

This right gives an individual an alternative to requiring data to be erased; in others, it allows the individual to require data to be held in limbo whilst other challenges are resolved.

If personal data are ‘restricted’, then the data controller may only store the data. It may not further process the data unless:

the individual consents; or

the processing is necessary for the establishment etc. of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important (Union or Member State) public interest.

5.4 Right to object to further processing

Any User may at any time exercise the right to opt-out from any further processing of personal data by Sources, by managing email settings or by choosing to unsubscribe via any email sent from the Source. By unsubscribing, Users personal information is deleted from the Source email list.

Users that have consented to process may at any time exercise their right to generally opt-out from the processing of personal data by deleting personal information from individual Sources email lists or by deleting their account in full. Note that further processing of personal data may still occur if a User has more than one email address registered to the Clipsource service.

5.5 Right to data portability

If the processing of a User’s personal data is based on consent, Users have the right to receive the personal data in a structured, commonly used and machine-readable format. 

5.6 Right to withdraw consent

When the processing of personal data is based on consent, Users have the right to withdraw consent at any time.

5.7 Right to file a complaint

Users may at any time lodge a complaint with the supervisory authority if they believe that the processing of personal data is performed in breach of applicable data protection law. Users can also contact the Source directly.

5.8 Other

If we make changes to this Privacy policy, we will publish an updated version here, where you will also have access to legacy versions of the policy.