Privacy Notice for data subjects in monitored content

Last Updated: March 2022

At Meltwater, we know that you care about how your personal data is used and shared, and that is why we are committed to transparency around personal data, respecting your privacy and to helping you control the data we store.

In this notice (“Notice”) you will find information about what personal data we hold about you, how and why we collect it, how we use it, and how we protect it. This Notice also includes information about your rights, how to exercise those rights, and how to request the deletion of your personal data.

By "Meltwater", "Meltwater Group", "we", "us", or "our" we mean any of Meltwater The Netherlands B.V and its affiliates, in their capacity as an independent or joint controller of your personal data within the scope of this Notice. Contact details for Meltwater are set out at the end of this Notice.

Who this Notice applies to

This Notice applies to all data subjects whose personal data is included in the publicly available content Meltwater monitors, such as tweets, Facebook posts and news articles, excluding any personal data which is captured by our journalist privacy notice.

Why do we collect your personal data and how it is used

Meltwater is a global media intelligence organization and our products enable our customers (“Customers”) to monitor publicly available online content, such as editorial and social media content, by using certain keywords. Customers are interested in knowing how their brand performs compared to their competitors, what the media trends are for their industry and what has been written about topics close to their interests. Our Customers access our services via our online platform and/or mobile application where they can view content matching their queries.

Content and search results delivered by Meltwater to Customers, based on their keywords, may include your personal data. For example, your personal data may have been included in a news article, or your social media post may have included a key word which is picked up by the searches on the online platform. The collection of your personal data is incidental to Meltwaters’ and our Customers' main purposes of monitoring editorial and social media. We receive your personal data because we provide the online platform and technology which powers this monitoring activity. We use your personal data to provide our services to Customers, and for the purposes of displaying, analysing and storing relevant content. For social media monitoring, our services may also recognize social media accounts, which often publish content including the keywords of the relevant search. We also allow Customers to search monitored content by author, allowing them to find news articles or social posts written by a specific person.

What personal data we collect

The personal data we collect is limited to the personal data included in news articles, websites or social media platforms, such as name and approximate location (if enabled). Whilst it is not Meltwaters’ or our Customers' goal to collect special categories of personal data about you, this type of personal data may be present in some monitored content (such as in a public article about a person battling a disease or disability). Meltwater does not collect personal data about you to create any profiles or conduct profiling of you as a data subject.

How we collect your personal data

The personal data we hold about you is obtained directly from publicly available sources, including public social media platforms, websites and online newspapers. We do not collect personal data about you from any other sources (unless provided to Meltwater in accordance with our Privacy Policy).

Legal basis for processing your personal data

We use your personal data for the purposes outlined above, and we must have a legal basis to justify these use cases. We process your personal data to provide services to our Customers. The processing is therefore based on our and our Customers’ legitimate business interests (Art. 6 para. 1 f of both the EU GDPR and UK GDPR). We consider and balance any potential negative impact on you and your rights before we process your personal data for our legitimate interests. We have assessed that our use of this personal data is necessary and is not outweighed by your interests. We have safeguards in place to ensure we do not use your personal data for activities where we believe that our interests are overridden by any unwarranted adverse impact on you.

Where we collect special categories of personal data about you, we need an additional legal basis. We rely on the fact that the special categories of personal data about you have been manifestly made public to justify our use of this type of personal data (Art. 9 para. 1 e of both the EU GDPR and UK GDPR).

How we share your personal data and with whom

We may share your personal data with one or all of the following:

Customers: our Customers are typically communications and marketing departments within businesses or other institutions, or PR agencies. Our Customers span all sectors, globally. (We share your personal data by allowing them access to our database through our online platform and authorizing them to search keywords through our online platform.)
Internal Third Parties: these include other companies within the Meltwater Group.
External Third Parties: Service providers, such as email delivery providers and data storage providers, whose services we contractually engage to provide the services to our Customers.

International transfers

We may share your personal data with entities within the Meltwater Group. This, as well as transfers to some of the third parties to whom we may transfer your personal data in accordance with this Notice, may involve transferring your personal data to countries outside of the European Economic Area (EEA) and the United Kingdom. We may transfer your personal data to countries like the United States of America, that does not provide for a level of data protection equal to that in EEA countries or to the United Kingdom. Where your personal data is transferred outside of the EEA or the United Kingdom, we do that on the basis of appropriate data protection safeguards, such as data protection clauses approved by the European Commission or the United Kingdom, in order to ensure that there is an adequate level of protection for your personal data. We will provide details of these safeguards to you upon request.

How long will we use your personal data?

We will keep your personal data for as long as is necessary for the purposes set out in this Notice and to fulfill our legal obligations to Customers. Generally, this means that we will retain the monitored content for 10 years when the personal data is included in news content, and 15 months when the personal data is included in social media content. The retention periods may vary depending on the arrangements that Meltwater has in place with the relevant media publisher or social platform.

If you request that Meltwater removes your personal data, we will delete any content containing your personal data from our services within a reasonable amount of time, subject to our legal obligations to retain such personal data. Please note, as the content is created by a third-party website, such as a newspaper or social media platform, we may receive new versions of your personal data in the future during our media monitoring operations.

Your rights

You have certain rights under applicable data protection laws in relation to your personal data. Your rights may depend on where you reside, and the rights granted to data subjects in the local legislation. If you wish to exercise your rights, please contact privacy@meltwater.com.

Depending on where you reside, your rights include the right to:

Access your personal data.
Require us to correct any mistakes in your personal data which we hold.
Require the erasure of personal data concerning you in certain situations.
Receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit personal data to a third party in certain situations.
Object to decisions being taken by automated means (including profiling) which produce legal effects concerning you or similarly significantly affect you.
Object in certain other situations to our continued processing of your personal data, where the processing is based on our legitimate interests.
Otherwise restrict our processing of your personal data in certain circumstances.

You also have the right to make a complaint at any time to your local data protection authority or, if you are in the EU, the Dutch Data Protection Authority, where Meltwater’s main establishment in Europe is located, for data protection issues. You may also contact the Privacy Commissioner of Canada (for international matters and inter-provincial matters) ( http://www.priv.gc.ca/).

Contact

If at any time you have any questions about this Notice or the way we use your personal data please contact our team, including our data protection officer, at privacy@meltwater.com

For individuals located in the European Union, please note that Meltwater has appointed Meltwater The Netherlands B.V, as its main establishment for data protection purposes in the European Union and the EU representative for any Meltwater UK based entity is Meltwater The Netherlands B.V. Meltwater The Netherlands B.V. can be contacted at the email address above or at Singel 250, 1016 AB, Amsterdam, The Netherlands.

For individuals located in the United Kingdom, please note that the UK representative of Meltwater’s EU based entities is Meltwater (UK) Limited. Meltwater (UK) Limited can be contacted at the email above or at 67-71 Shoreditch High St, London, United Kingdom E1 6JJ.