Somo ("we" or "us") is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data (as defined in Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) (PDPO) and the General Data Protection Regulation (GDPR)) we collect from corporate account holders or individual users or visitors to our Platform, or that is uploaded to our Platform, will be processed by us. Account holders, users and visitors of our Platform or owners of Personal Data collected by us (each, "you") should read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
By providing any Personal Data to us, you consent to the collection, use, disclosure and transfer of such Personal Data in the manner and for the purposes set out below.
We process users' personal data only in compliance with the relevant data protection regulations. User data is only processed if the following legal permissions exist:
The above legal bases are set out as follows:
We may collect and process the following data which may contain Personal Data:
If you contact us and send us general enquiries the contact details you provide, will be stored and used by us to fulfil the purpose associated with the transmission, e.g., to process your enquiry or in the event of follow-up questions.
The basis for this storage and use of your personal data is your consent which you give us by sending the contact form. Insofar as you provide us with your personal data for the purpose of responding to your questions, the entry of personal data is required as without this information, we cannot process your request.
You have the right to revoke your consent to the data processing described above at any time with effect for the future. In this case, we will no longer process your data. Your personal data will be deleted even without your revocation in any case if we have processed your request or if the storage is inadmissible for other legal reasons.
A user profile will be created for you based on the information you provide during the sign up. Your Email, Name, Profile Picture, Country, PayPal account data. You have the option of adjusting, changing, or deleting the information in your profile to edit within the app or by contacting our team.
The data processing carried out in this context is necessary to provide our service on the basis of the requests made by you. The data processing is also based on a legitimate interest, as our interest in providing users with a platform for exchanging information with other users does not conflict with any overriding interest or right of yours. It should be noted that the majority of the data you provide is voluntary.
As a registered user, you have the opportunity to create a user profile with just a few clicks and details. If you make use of the option, the relevant profile data you provide will be transferred to your profile. Of course, you can change the information at any time via the settings in your profile. When creating a profile, you can submit personal data such as your profile picture, property information, photos and images etc. Content and data are publicly viewable. You have choices about the information on your profile. You don't have to provide additional information on your profile; however, profile information helps you to get more from our Services. It's your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be available. The legal basis for the processing of your personal data is the establishment and implementation of the user contract for the use of the service. We store the data until you delete your user account. Insofar as legal retention periods are to be observed, storage also takes place beyond the time of deletion of a user account.
We process data in the context of administrative tasks as well as organisation of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.
In this context, we disclose or transfer data to consultants, such as legal advisors or auditors, as well as other fee offices and payment service providers.
Furthermore, based on our business interests, we store information on suppliers and other business partners, e.g., for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.
We take appropriate technical and organisational measures in accordance with the law, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the level of threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
However, you must understand that no web site or Internet transmission is completely secure. Therefore, we can never guarantee that unauthorised access, hacking, data loss and other incidents can be completely excluded.
We may also collect and process information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our business partners. This is statistical data about our users' browsing actions and patterns and does not identify any individual.
We only collect and process access data that your internet browser automatically transmits to us for technical reasons in order to provide the website. Depending on the access protocol used, the protocol data record contains general information with the following contents: Your session data (usage behaviour, length of stay, which links were clicked on, etc.), your abbreviated and unabbreviated IP address, your browser version, your operating system, your website-specific settings, your cookie IDs, your pixel IDs. This data does not allow any direct inference to your person and is processed to improve our website offer and to defend against attempted attacks on our web server. The legal basis for the processing of your personal data is our legitimate interest. We have a legitimate interest in presenting you with a website optimised for your browser and in enabling communication between our server and your device.
For the processing of personal data using cookies and similar technologies on our website, please refer to our Cookie Policy, which is part of this privacy policy. The legal basis for the processing of your personal data is our legitimate interest. We have a legitimate interest in presenting you with a functional, secure and user-friendly website. As well as your consent in case you agree to our use of cookies.
The Personal Data that we collect may be transferred to, and stored at, a destination outside Hong Kong and stored and used in global data centres of Amazon. It thus may also be processed by staff operating outside Hong Kong who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your services ordered by you, the processing of your payment details and the provision of support services. By submitting any Personal Data to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this privacy policy.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Payment processing takes place at PayPal Hong Kong Ltd, Room 1506-07, 15/F, Central Plaza, 18 Harbour Road, Wan Chai Hong Kong. The data processing thus serves the fulfilment of the contract. For further information on data protection law, please refer to PayPal's Privacy Policy.
We use information held, including Personal Data, in the following manner:
We may disclose your Personal Data to any member of our group, which means any corporation deemed to be related to.
We may disclose your Personal Data to third parties:
By providing your Personal Data to us, you consent to the collection, use and disclosure of your Data by us for the purposes set out in this privacy policy ("Purposes").
Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party's prior consent for our collection, use and disclosure of their Personal Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us.
Each use of our services by you shall constitute a fresh agreement for us to collect, use and disclose the Personal Data in accordance with this privacy policy.
You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the Purposes by submitting your request to us in writing to support@somo.me. Should you withdraw your consent to the collection, use or disclosure of your Personal Data, it may impact our ability to proceed with your transactions, agreements or interactions with us. Prior to you exercising your choice to withdraw your consent, we will inform you of the consequences of the withdrawal of your consent. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.
The PDPA gives you the right to access your Personal Data. Your right of access can be exercised in accordance with the PDPO and the GDPR. Any access request may be subject to a fee of an administrative fee at our rates then in force to meet our costs in providing you with details of the information we hold about you.
In the event that you wish to correct and/or update your Personal Data in our records, you may inform us in writing of the same by sending us an email at support@somo.me. In certain cases, Personal Data may also be corrected or updated via the Platform.
We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPO and the GDPR).
We endeavour to ensure that all decisions involving your Personal Data are based upon accurate and timely information. However, we rely on you to disclose all relevant information to us and to inform us of any changes in your Personal Data. As such, please disclose all relevant information necessary for us to provide services to you and ensure all information submitted to us is up-to-date, complete, and accurate. Kindly inform us promptly if there are any changes in your Personal Data.
We may retain your Personal Data for no longer 30 days, or such other longer or shorter period as may be necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain your Personal Data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected and is no longer necessary for legal or business purposes.
Our Platform may, from time to time, contain links to and from the websites of our partner networks, business partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Data to these websites.
Where we process your Personal Data as a data intermediary on behalf of a third party, we will process your Personal Data in accordance with the instructions of the third party and shall use it only for the purposes agreed between you and the third party. All such Personal Data will be protected and retained in accordance with this privacy policy and the terms of the PDPO and the GDPR.
We will take steps to inform the third party of any requests, complaints or questions that you may have regarding such Personal Data.
The data protection laws in your country may give you the following rights:
If you wish to exercise any of the rights listed above, you can contact us by email at support@somo.me. For your protection and the protection of all our users, we may need to request certain information from you to help us confirm your identity before we can respond to the above requests.
If you feel that we have not resolved your concern, you have the right to make a complaint at any time. You can also contact your local data protection supervisory authority.
By granting SOMO access to your YouTube account, SOMO may access the following information: publicly available personal information, your videos and playlists, and your YouTube activities. Your information may be used by advertisers to view and facilitate partnerships with you. All account information will be used for creator's details and creation of collaborative works. The above information will be stored on SOMO servers and we will keep it safe.
By granting SOMO access to your Facebook and Instagram accounts, SOMO may access the following information: public profiles and pages, Instagram work, and Instagram activities. Your information may be used by advertisers to view and facilitate partnerships with you. All account information will be used for creator's details and creation of collaborative works. The above information will be stored on SOMO servers and we will keep it safe.
Applies to All Customers - Google Privacy Policy
Applies to All Customers - YouTube API Terms of Service
Applies to All Customers - Terms of Service
The data index like SOMOScore/Est. Partner Earning/Est. Potential Earnings/Est. Cooperation Views/Audience Insight Data/Global Hot Trends is calculated by SOMOInfluencer, the data source is not from YouTube API. SOMOInfluencer use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
To revoke SOMO's access to users data via the Google security settings, all users may find the page at https://security.google.com/settings/security/permissions
Any changes we may make to our privacy policy in the future will be posted on our Platform and, where appropriate, notified to you by e-mail.
Questions, comments and requests regarding this privacy policy are welcome and should be addressed to support@somo.me.