Privacy Policy

TheTriangleLab Limited (“Kyra”, “us”, or “we”) is the “data controller” in respect of your personal information.

This privacy notice sets out the basis on which any of your personal information we collect from you or third parties, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal information and how it will be treated.

For some processing, we are “joint controllers” with certain brands in respect of your personal information (for example, when we produce data analytics reports to brands in respect of use of the services). Should you wish to exercise any of your data rights (as described below), or have any questions about this arrangement, please contact us using the contact details below.

WHO DOES THIS PRIVACY NOTICE APPLY TO?

This privacy notice applies to:

creators using our services, including creators who access the Kyra One platform to manage campaign deliverables, receive payments, or view analytics (e.g. via the Kyra One portal, our app, or other services Kyra may provide);
individuals working on behalf of brands who may use our services (e.g. the Kyra One platform, our app, or other services Kyra may provide), including employees and contractors who access the platform to manage campaigns, discover creators, or use analytics tools; and
individuals who may visit our website or view our content.

HOW AND WHEN WE COLLECT PERSONAL INFORMATION ABOUT YOU

We collect and process personal information: (1) when you provide it to us; (2) which we may automatically collect from you; and/or (3) which we may collect from third party sources.

Personal information which you provide to us and/or we collect automatically

We collect personal information which you provide to us and/or which we may collect automatically when you:

visit our website and/or app (including when registering on our site for our newsletter or leaving any reviews or comments);
purchase and/or subscribe to any of our services (including when you sign up);
contact our customer service or request information from us in any other way;
search for, interact and collaborate with brands or creators on our website, app and/or social media channels (including data about your interests and preferences as well as any inferences drawn from them);
participate in discussion on social media or enter competitions;
participate in our customer satisfaction surveys or other market research which may include profile data about your interests, preferences (including inferences about them), feedback and survey responses; and/or
communicate with us via social networking websites, third party apps or similar technologies.

Third party sources:

We may also collect information about you from third party sources, such as when you give us permission to access data about you via any third party API (including, but not limited to, the Instagram, Facebook, YouTube and TikTok APIs), or through Stripe in relation to payment. For further information on how these third parties process your personal data, please see the below:

Instagram: https://privacycenter.instagram.com/policy
Facebook: https://en-gb.facebook.com/privacy/policy
YouTube: https://policies.google.com/privacy?hl=en-GB

In addition to the normal procedure for deleting stored data, you will be able to revoke the data of YouTube API Services via the Google security settings page at https://myaccount.google.com/permissions.

TikTok: https://www.tiktok.com/legal/privacy-policy-eea?lang=en

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU

Personal information which you provide to us

We may collect and process the following personal information about you which you provide:

contact details (such as your name, address, email address and telephone number);
demographic information (such as age and/or other information that may identify you as an individual);
password and other authentication information;
photograph (for example as part of your profile photo on our platform);
responses to any customer satisfaction surveys or market research (unless these are provided anonymously);
your social media profile information;
financial and payment information (including payment details processed via Stripe Connect where you use the Kyra One platform to make or receive payments); and
your marketing preferences.

Personal information which we may automatically collect from you

When you visit our website and/or app, we may also collect information from you automatically, for example using cookies and other similar technologies. A cookie is a small file of letters and numbers that we may set on your device. Cookies generally only work with web browsers, but there are similar technologies that are used with apps.

This type of information, collected by cookies and similar technologies may include the following:

information about your device (including a unique device identifier or device ID), operating system and IP address;
your login information;
browser type and version;
information about your visit on our website or app, including URL, clickstream (i.e. your journey to, through and from our site), pages you’ve searched for and viewed, length of visits to certain pages, and page interaction information; and
information about your use of our app, for example to distinguish you from other users of our app, and to remember your preferences which helps us to provide you with a good experience when you use our app and also allows us to improve the app.

Product-Seeding Campaigns

When we offer complimentary products to creators , we collect the contact, social-media and shipping information you voluntarily provide.

Purpose. To verify eligibility, dispatch the product and confirm delivery.
Disclosures. Data are shared only with the brand owner detailed in any seeding form and our contracted fulfilment or courier service for the purposes stated above.
Legal basis / notice at collection. Consent under Article 6 (1)(a) GDPR, or, where applicable, as a “notice at collection” under U.S. state privacy laws. We do not sell or share this information for cross-context behavioural advertising.
Retention. Records are stored in secure systems and deleted or anonymised within twelve (12) months of fulfilment, unless a longer period is required to resolve delivery-related issues.
Your rights. You may exercise your statutory rights (access, correction, deletion, objection, restriction, portability or appeal) by contacting us at hello@kyra.com.

Stripe Connect Payment Processing

Where you use the Kyra One platform to make or receive payments to creators, your payment information is processed by Stripe, Inc. (“Stripe”) via Stripe Connect. Kyra does not store or have access to your full payment card details. Stripe processes your payment data in accordance with the Stripe Privacy Policy (https://stripe.com/privacy). We receive limited transaction information from Stripe (transaction amounts, dates, and status) to operate the platform, reconcile payments, and resolve disputes.

Legal basis: Performance of a contract (processing payments you have agreed to make or receive via the platform) and our legitimate business interests (platform operation and fraud prevention).

AI and Automated Decision-Making

The Kyra One platform uses artificial intelligence and machine learning tools to generate creator scores, recommendations, brand safety assessments, audience analytics, and content compliance checks. These tools process publicly available data (such as social media posts, engagement metrics, and audience demographics) together with platform usage data. AI-generated outputs are provided on a best-efforts, informational basis and do not constitute guarantees of creator performance or content quality.

Where automated processing produces outputs that may significantly affect you (such as creator ranking or brand safety flags), you have the right to request human review of any automated decision. Contact us at hello@kyra.com to exercise this right.

Legal basis: Our legitimate business interests (improving the platform, generating insights, and ensuring brand safety).

Platform Telemetry

We collect anonymised usage information generated from your use of the Kyra One platform, such as feature usage patterns, dwell times, navigation flows, and interaction data (“Telemetry”). Telemetry does not identify any natural person. We use Telemetry to improve the platform, generate industry benchmarks, and develop our services. Telemetry may be aggregated and shared with third parties in anonymised form.

Legal basis: Our legitimate business interests (improving the platform and developing our services).

Cookies and similar technologies

Some cookies may expire each time you close your browser and do not remain on your device afterwards, and link your actions during a particular browser session (session cookies), whilst others remain on your device until they expire or you delete them from your cache, and are stored on your device in between browser sessions allowing for your preferences or actions across the site to be remembered (persistent cookies). The cookies we use fall into the following categories:

Strictly necessary cookies: These cookies are essential for you to be able to navigate the site and use its features. Without these cookies, the services you have asked for could not be provided.
Performance cookies: These cookies collect information about how you use our site, e.g. which pages you go to most often.
Functionality cookies: These cookies allow the site to remember the choices you make (such as your user name, language, last action and search preferences) and provide enhanced, more personal features.

If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies or otherwise withdraw your consent in relation to cookies, you may not be able to access all of the functions of the site.

PURPOSES FOR PROCESSING YOUR PERSONAL INFORMATION

We may process your personal information for the following purposes:

to provide you with the information, products and/or services you have requested (for example, if you’re an influencer, to connect you with brands, help to provide you with opportunities and display your profile data on our app);
to authenticate your access to our website and our app;
for system administration purposes and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to distinguish you from other users (for example to remember your log-in details);
to monitor your use of our website and app to improve the user experience and to ensure that content is presented in the most effective manner for you and for your device;
to provide customer support and ensure we provide a good level of customer service;
to send you marketing and advertising materials and to tailor any marketing or advertising so that it is more relevant to you;
to notify you of any changes to our services;
to conduct marketing analysis to allow us to assess trends and the effectiveness of advertising and marketing campaigns (including using your personal information to evaluate, analyse or predict certain personal aspects relating to you, such as your preferences, economic situation, interests, and/or location);
to create “audiences” for the purposes of personal advertising made up of other individuals who share similar characteristics with you and whose interests, attributes and/or preferences we can therefore infer;
if you are filmed, photographed or recorded as part of any onsite activities/one of our events, your image or likeness may be used in promotional material, sponsor, exhibitor and media partner coverage in print, online and/or on broadcast television;
to match personal information that you provide to us directly with other information about you obtained from or held by third party sources (such as social media platforms). This may include your contact details, demographic data, your social media interactions, preferences, habits, interests, geographic location and age or age range. We may use this personal information to:
provide our services to you; and/or
to tailor and show advertisements more relevant to you either on our website or on third party websites (including social media platforms).

to facilitate marketplace transactions between brands and creators on the Kyra One platform, including matching brands with suitable creators, processing campaign briefs, managing content approval workflows, and facilitating payments via Stripe Connect;

to generate creator scores, analytics, audience insights, and brand safety assessments using AI and machine learning tools, for the purpose of improving the quality and relevance of our marketplace services;

to ensure that our website and app is safe and secure; and
for security and fraud prevention and to comply with applicable laws and regulations.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.
Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively as a media company, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights. For example we will rely on this legal basis when we conduct certain market analysis to understand our clients in sufficient detail so we can develop our services.
Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased our services and we need to use your contact details and payment information in order to process your request for our services.
Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

WHERE WE STORE YOUR PERSONAL INFORMATION

The personal information that we collect may be transferred to, and stored at, a destination outside the EEA or the UK, including countries which have less strict, or no data protection laws, when compared to those in the EEA or the UK.

Whenever we transfer your information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy notice. In these cases, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country.

If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

HOW WE KEEP YOUR PERSONAL INFORMATION

We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.

Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.

SECURITY AND PASSWORDS

You must keep your password and any other authentication information for our website and app confidential. If you know or suspect that anyone other than you knows your password or any other authentication information, you must promptly notify us using the contact details below. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted during your use of our website and app.

Our website and app may, from time to time, contain links to and from third party websites and services such as our business partners and advertisers. If you follow a link to any of these websites and/or services, please note that they have their own privacy notices and we do not accept any responsibility or liability for them. Please check any such third party privacy notices before you submit any personal information to these websites or services.

DISCLOSING YOUR INFORMATION

We may share your personal information:

within our group of companies (i.e. our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006);
with business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, in particular where they are helping us to market and advertise our services as well as providing our services to you. This includes sharing your personal information with our client brands where or not you have signed up and/or use our platform/app/services (for example to connect you with brands etc);
to advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
to analytics and search engine providers that assist us in the improvement and optimisation of our site and similar third parties for the purposes of research, evaluation, and analysis;
to credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you and to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply our terms and conditions;

with Stripe, Inc. and its affiliates for the purpose of processing payments between brands and creators on the Kyra One platform via Stripe Connect;

in the event that we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets;
if we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers and visitors to our websites will be one of the transferred assets; and
if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request.

ADDITIONAL RIGHTS FOR US RESIDENTS

If you are a resident of California or another US state with applicable privacy legislation (including the California Consumer Privacy Act / California Privacy Rights Act, the Virginia Consumer Data Protection Act, the Colorado Privacy Act, or similar state laws), you may have additional rights regarding your personal information. These include:

Right to know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purpose for collection, and the categories of third parties with whom we share it.

Right to delete: You may request that we delete personal information we have collected from you, subject to certain exceptions (such as where retention is necessary to complete a transaction, comply with a legal obligation, or detect security incidents).

Right to correct: You may request that we correct inaccurate personal information we hold about you.

Right to opt out of sale or sharing: We do not sell your personal information. Where we share personal information for cross-context behavioural advertising, you may opt out by contacting us at hello@kyra.com.

Right to non-discrimination: We will not discriminate against you for exercising any of your privacy rights.

To exercise any of these rights, please contact us at hello@kyra.com. We will verify your identity before processing your request and respond within the timeframe required by applicable law (generally 45 calendar days, extendable by an additional 45 days with notice). You may also designate an authorised agent to make a request on your behalf.

YOUR RIGHTS

You have certain rights in relation to your personal information. These include:

the right to object to the processing of your information for certain purposes;
the right to access or rectify your personal information; and
the right to request the ability to erase, restrict or receive a machine-readable copy of your personal information.

We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights please contact us using the contact details below.

You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns we request that you initially contact us (using the contact details below) so that we can investigate, and hopefully resolve, your concerns.

CHANGES TO THIS PRIVACY NOTICE

We may change this privacy notice at any time. The new privacy notice will be displayed on our website and app. The date this privacy notice was last updated appears at the bottom.

CONTACT US

Questions and comments regarding this privacy notice should be sent to: hello@kyra.com
Our registered offices are located at: 8 Warner Yard, London, England, EC1R 5EY