Privacy Statement

This privacy statement is relevant to consumers (“Consumers”, “their”, “them”) as they make information about themselves available on public websites. It talks about how we use their personally identifiable information (“data”) as part of the services which we offer to our customers and what their rights are regarding that data.

Our Privacy Notice for California Residents supplements the information contained in this privacy policy and applies solely to those who reside in the State of California.

WaveMetrix collects data about Consumers for research purposes. We focus on entertainment brands and products. If Consumers discuss entertainment brands or products publicly online then we may use their discussion as part of our data.

1. General

1.1. We are WaveMetrix Ltd (“we”, “us”), a company registered at 150 Minories, London, EC3N 1LS. Our company registration number is 5288384

1.2. We collect, and are the controller of, data which Consumers make publicly available online. In some cases, we are supplied that data by third parties. We store this information in our databases and may make it available to our customers

1.3. This privacy statement contains information about Consumers’ rights and the protections we provide when we collect their data

2. Anonymity

2.1. To protect Consumer privacy, we anonymise data about Consumers as far as practically possible. This means that we will not store or share their full name unless they are a public figure, as indicated by their social media account (usually by the fact that the account is verified) or by other publicly available information about them, such as their Wikipedia page, and will not store or share their online handle or username if it is reasonably practical to avoid doing so.

3. What we collect

3.1. Information we collect about Consumers may include the following:

a. their name, username, handle, or other identifier (subject to our anonymity policy);

b. the content of the information they have published via that name, username, handle, or other identifier, including comments, expressions, opinions, posts, etc.;

c. their interests and fandoms;

d. their location;

e. their gender;

f. the list of users they follow or subscribe to; and

g. any other information they publish on an Internet website we crawl or on a third party platform that provides us with data

3.2. We also infer other information based on what Consumers make publicly available. For example, if they say (perhaps in their public profile) that they are male and have children, we may infer that they are a father

3.3. We may analyse the data Consumers make publicly available in order to provide insight to our customers. For example, if they comment about a movie trailer, we may analyse and record what they say they do and don’t like about it

4. How we collect and use Consumer data

4.1. Our data collection has, as its legal basis, our legitimate interest in running a research business and collecting data to serve this purpose. We firmly believe that our research benefits both clients and consumers and we continually assess the impact of our data collection to ensure that it continues to reflect our core values

4.2. We may also collect and use data on behalf of our clients, based on their legitimate interests, which include creating and selling consumer products and controlling the distribution of their copyrighted material

4.3. We may infer data about Consumers automatically, based on what they make publicly available online, but do not use this information to make any automatic decisions about them. We continually take steps to ensure that all data we infer about them is as accurate as possible

4.4 Customers may use Consumer data in ways not listed here, provided that use is within reasonable expectations

5. How we share Consumer data

5.1. We share Consumer data within our company in the course of processing it

5.2. We may share Consumer data with our customers. This usually takes the form of aggregate statistics, but may take other forms, such as direct quotes or links to social media posts they have made

5.3. We also share Consumer data with a number of selected and carefully vetted third parties (our partners, subcontractors and suppliers)

5.4. We may also share Consumer data with other third parties in the case that we buy or sell business assets, or are bought or sold as a business, subject to the purposes of the use of the data remaining substantially the same

5.5. All data sharing we do, internally and externally, is subject to our anonymity policy

5.6. In addition, whenever we make Consumer data available to a third party, we make sure appropriate safeguards are in place to ensure that their data remains protected

6. How we store and retain Consumer data

6.1. We may transfer data to other countries other than the Consumer’s own for storage, which may include countries where the law does not provide a similar level of protection. Where this happens, we ensure that appropriate safeguards are in place and that those who handle the data are bound to respect them

6.2. Similarly, we ensure that all servers where we store Consumer data have appropriate technological and procedural safeguards

6.3 We continue to store data as long as it remains relevant to the research we are doing, which can include long-term retention for historical benchmarking purposes. As we explain below, Consumers can contact us to request that we delete data we hold about them

7. Consumers’ data rights

7.1. Consumers have a number of legal rights concerning their data under privacy law. They may:

a. request access to the data that we have about them and request that it be updated, rectified, deleted, or blocked; or

b. request that we refrain from further use of any data we hold about them

7.2. To exercise any of these rights, Consumers can email privacy [at] wavemetrix.com or send us post at the address listed above

7.3. Consumers have the right to complain about our processing of their data to the data protection authority in their country. For example, in the UK they could submit a complaint at https://ico.org.uk/concerns/

8. Governing law and jurisdiction

8.1. English law governs this privacy statement and any dispute or claim related to it. Each party agrees that the English courts have exclusive jurisdiction over this privacy statement and any dispute or claim related to it


Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in the Privacy Statement of WaveMetrix Ltd. (“we”, “us”) and applies solely to those who reside in the State of California (“consumers”, “they”, “their” or “them”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

  • Category A – Identifiers

Examples: Name, or other similar identifiers.

  • Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Examples: Education or employment information.

  • Category C – Protected classification characteristics under California or federal law

Examples: Age, ethnicity, citizenship, religion or creed, marital status, physical illness, mental illness or disabilities, gender, veteran status.

  • Category F – Internet or other similar network activity.

Information about how consumers interact (publicly) while on social media, public information about who users of social platforms follow or subscribe to.

  • Category I – Professional or employment-related information.

Examples: Occupation.

  • Category K – Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences.

Examples: Fan of superhero movies.

We obtain the categories of personal information listed above from the following categories of sources:

  • Indirectly from consumers when they comment publicly on social media sites about topics relevant to our clients and their products.

  • Directly from social media sites who make this information available to us.

Use of Personal Information

We may use the personal information we collect for one or more of the following business purposes:

  • For testing, research, analysis and product development.

  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Sharing Personal Information

We do not sell or disclose consumer personal information to our clients. We only transfer information which has been either aggregated or de-identified, so consumer personal information does not leave our systems.

In the preceding twelve (12) months, we have not sold any personal information.

Consumer Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

Consumers have the right to request that we disclose certain information to them about our collection and use of their personal information over the past 12 months. Once we receive and confirm a verifiable consumer request, we will disclose:

  • The categories of personal information we collected about the consumer.

  • Our business or commercial purpose for collecting that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about the consumer (also called a data portability request).

 Deletion Request Rights

Consumers have the right to request that we delete any of their personal information we collected and retained, subject to certain exceptions. Once we receive and confirm a verifiable consumer request, we will delete (and direct our service providers to delete) the personal information from our records, unless an exception applies.

We may deny a deletion request if retaining the information is necessary for us to:

  1. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  2. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  3. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

  4. Comply with a legal obligation.

 Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at privacy [at] wavemetrix.com or leave a message on our freephone line +1 (800) 940-6215.

Only a consumer or a person registered with the California Secretary of State that they authorize to act on their behalf, may make a verifiable consumer request related to their personal information. A consumer may also make a verifiable consumer request on behalf of their minor child.

A consumer may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify they are the person about whom we collected personal information or an authorized representative.

  • Describe their request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to their request or provide them with personal information if we cannot verify their identity or authority to make the request and confirm the personal information relates to them.  Making a verifiable consumer request does not require the consumer to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform the consumer of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at the consumer’s option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide the personal information that is readily useable and should allow the consumer to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell the consumer why we made that decision and provide them with a cost estimate before completing the request.

Non-Discrimination

We will not discriminate against any consumer for exercising any of their CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny use of our Services.

  • Provide a different level or quality of Services.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the bottom of this page. The consumer is responsible for periodically visiting the WaveMetrix website and this Privacy Notice to check for any changes.

Contact Information

If any consumer has any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use their personal information, their choices and rights regarding such use, or wish to exercise their rights under California law, they may contact us via email at privacy [at] wavemetrix.com or leave a message at our freephone line +1 (800) 940-6215.

This privacy notice was last updated March 2023.