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The European Commission adopted the General Data Protection Regulation (“GDPR”). The GDPR applies from 25 May 2018. The GDPR replaces the 1995 Data Protection Directive (“Directive”). The GDPR is, essentially, an upgrade from the Directive. The purpose of this FAQ is to set out for our customers how PeopleBrowsr is approaching the GDPR and data privacy generally. If you have any questions that are not answered by this FAQ, please reach us via the contact page.

Data Privacy FAQs
[fa icon="plus-square"]Does PeopleBrowsr comply with the GDPR?
Yes
[fa icon="plus-square"]Does the GDPR apply to PeopleBrowsr’s services?

The GDPR applies to the processing of personal data. Personal data means any information relating to an identified or identifiable natural person. PeopleBrowsr offers a variety of services, each of which require a different analysis under the GDPR.

SocialOS

Domain Registrants

Kred Scores

Crypto.Kred

[fa icon="plus-square"]Is PeopleBrowsr a data controller or a data processor with respect to its Kred Scoring and social feeds services?
For its Kred Scoring and social feeds services, PeopleBrowsr makes decisions about which websites it crawls, what data it collects, and how and why this data is used in connection with its services. This decision is based on the fact that these services and any related processing are not specific to any particular customer and could not therefore be said to be only “on the instructions” of any such customer. Therefore, for the Kred Scoring and social feeds services that contain personal data, PeopleBrowsr considers itself a data controller under the GDPR.
[fa icon="plus-square"]Is PeopleBrowsr a data controller or data processor with respect to SocialOS?
Historically, SocialOS only displayed data from PeopleBrowsr's other applications. Where only data from PeopleBrowsr's applications is displayed, PeopleBrowsr is still a data controller. This is because the data that SocialOS is processing is PeopleBrowsr's own data source (for which PeopleBrowsr is a data controller). However, PeopleBrowsr has built a developer ecosystem that allows its customers to build their own software applications to sit on top of SocialOS, displaying customers’ own data. Where a customer has built their own software application, and that application has personal data in it, PeopleBrowsr is a data processor and the customer is a data controller of that personal data. This is because PeopleBrowsr is only processing personal data on the customer’s behalf (i.e. to run and operate the customer’s application).
[fa icon="plus-square"]If PeopleBrowsr is a data controller for its Kred Scoring and social feeds services, what are its customers?
For all of its Kred Scoring and social feeds services, PeopleBrowsr's customers are also data controllers in respect of the personal data which customers process through the use of the Kred Scoring and social feeds services. The reason is that, under the GDPR, a person must be a data processor or a data controller. A data processor processes data on behalf of the data controller. Since PeopleBrowsr’s customers do not process personal data on PeopleBrowsr’s behalf, PeopleBrowsr’s customers must be data controllers under the GDPR for PeopleBrowsr's Kred Scoring and social feeds services.
[fa icon="plus-square"]What is the legal basis on which PeopleBrowsr processes personal data for its Kred Scoring and social feeds services?
The primary legal basis on which PeopleBrowsr processes personal data when performing its Kred Scoring and social feeds services is the legitimate interests of the data controller. This legal basis requires a balancing of the legitimate interests of the data controller with the interests or fundamental rights and freedoms of the data subject which require protection of personal data. The data that PeopleBrowsr processes from its Kred Scoring and social feeds services is all publicly available – and made available – by the particular social media author him or herself. PeopleBrowsr therefore believes that the interests, fundamental rights and freedoms of data subjects are not prejudiced or overridden in the context of its processing of social media data that is (1) publicly available and (2) can be made private at anytime by the social media author him or herself. The social media authors have significant levels of control over the availability of their personal data on the underlying websites, including (e.g.) setting their Twitter account to private.
[fa icon="plus-square"]How does PeopleBrowsr ensure its services comply with the GDPR?
PeopleBrowsr has appointed privacy champions on its engineering and product teams. These individuals are tasked with incorporating privacy by design principles when developing services for PeopleBrowsr. PeopleBrowsr also implements Privacy Impact Assessments, where required, in accordance with the GDPR. Finally, PeopleBrowsr has an information security engineer and legal counsel that oversee privacy-related matters.
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