In compliance with the information obligation under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) – hereinafter referred to as “the GDPR”, we hereby declare that:
This privacy notice applies to individual natural persons who have been included in the Media Discovery module of Prowly.com sp. z o.o. with its registered office in Warsaw.
We seek to provide journalists and influencers with all necessary information about how their personal data are processed. This document contains all relevant information about what data we store, how and why we collect these data, how we use them and what measure we take to secure them. This privacy notice also provides information about the rights, how to exercise these rights and how the law protects journalists and influencers.
What media discovery is
Media Discoveryis a search engine built into the Prowly app, with which our clients can easily and quickly search not only for contacts and information about journalists and influencers, but also, e.g., for links to their publications or links to their social media profiles.
Why are we doing this? To help our clients better communicate their media information to the right people and make their information more relevant to the needs of journalists and influencers.
Therefore Media Discovery, a repository of information (especially contact information) concerning people who have the ability, through their daily work, to influence the opinions of others. This is information about traditional journalists working for information publications (printed and online), independent journalists, bloggers and others who influence public opinion (influencers). All Media Discovery features are available only to our subscribers.
With respect to the processing of personal data as specified below, the Controller of the personal data of journalists and influencers is Prowly.com sp. z o.o. (with its registered office in Warsaw at ul. Madalińskiego 71/1).
The contact details of the Controller are: firstname.lastname@example.org
The contact details of the Data Protection Officer are: email@example.com
What kind of data do we collect
We limit our searches to information that we believe will enable us to contact those who may be potentially interested in accessing our clients’ content.
The data to be shared shall include basic information such as:
- Full name,
- Publicly available contact details (email address, telephone),
- Current position,
- Current workplace (if publicly available),
- Links to social media profiles,
- Number of followers (where this information is publicly available),
- Interesting topics on which the person delivers his or her opinion,
- The industry he or she is working in,
- Links to the most important articles published online under his or her name.
All data collected by us are publicly available and easy to find online.
How we collect journalists and influencers' personal data
We search for personal data about journalists and influencers in publicly available sources such as:
- articles written by a given journalist or influencer,
- blogs authored by a given journalist or influencer,
- video materials shared by these persons,
- own website of a journalist or influencer,
- their employer’s website, if such data is made public,
- publicly accessible social media profiles (e.g. Facebook, Instagram, Twitter, LinkedIn),
- other publicly available online sources.
We do not collect or process any sensitive or confidential data such as data relating to race or ethnic origin, religious or philosophical beliefs, sexual life, sexual orientation, political views, trade union membership, health, genetic data or biometric data.
The purpose of using the personal data of journalists and infuencers
The main objective of Media Discovery is to enable our clients to search for information on journalists and influencers, to create new or expand their existing media base and to communicate with them more effectively and in a tailored way, by:
- sending out press releases: our clients can send press releases to journalists and influencers on topics that will interest them,
- creating a personalized media contacts database: our clients can create lists of journalists and influencers,
What’s in it for journalists and influencers? Thanks to a personalized search engine, they can receive more relevant press releases.
Search results are made available to our clients for a fee.
The legal basis for data processing
We process the personal data of journalists and influencers in order to provide services to our clients. This is in our legitimate business and legal interest and is based on Article 6(1)(f) of the GDPR.
We inform our clients of the need to obtain the consent of specific journalists and influencers for communicating marketing information and carrying out other activities related to their personal data. In the event that our client uses the personal data of a journalist or influencer collected through Media Discovery, he or she becomes the Controller of such personal data and is therefore obliged to provide detailed information on the manner and purpose of the processing of personal data so that the processing is in compliance with the applicable legal provisions.
We do not use your personal data for activities in which we consider that our interests take precedence over any unreasonable negative impact on the journalist or influencer concerned.
When making the personal data in question available to our clients, we use ONLY information that is publicly available online. However, if a given person, whose data are available via Media Discovery, would like us to correct, complete or delete their data from our search engine, we invite this person to contact us at firstname.lastname@example.org
Emails and press releases sent by our clients via Prowly may include tracking software to inform them if and when you read the email sent and whether you clicked on the links contained therein.
We may use the personal data of journalists and influencers included in Media Discovery for the purpose of automated profiling. The profiling activity that we are pursuing and its methods are limited. We use profiling to evaluate interests and the industry in which a given person functions and to make search results available to our clients in response to specific inquiries formulated with our app.
For example, we may use profiling to help our clients search for articles written by a journalist, or to determine the size of the audience (resulting from, e.g., the number of users following the person concerned in social media). This, in turn, helps our clients to communicate more effectively with selected media representatives.
We undertake to protect your personal data and implement various security measures to maintain the security of your personal data in accordance with industry standards and the provisions of the GDPR.
Please be informed that the personal data of journalists and influencers will not be disclosed to external entities, i.e. entities other than our clients who requested such data.
Personal data will not be transferred to any third countries or international organizations.
Journalists and influencers may at any time demand access to their personal data, request their data to be rectified or deleted, or request restriction their processing. They also have the right to object to the processing of their personal data and the right to have their personal data transferred.
At any stage of data processing, a person whose data are processed by us may file a complaint with a supervisory authority (the President of the Office for Personal Data Protection or any other competent authority), should he or she consider that the processing of their personal data violates the provisions of the GDPR.
Journalists and influencers have the right to object to the processing of their personal data because of a special situation they have indicated, which should be specified each time.
For how long we are going to process your personal data
We will process the personal data of journalists and influencers for the period necessary for the purposes set out in this document or until the data subject objects to their processing.