Privacy Policy

1. Who we are

Mana is a creator intelligence and discovery platform operated by GTM Labs SL.

This Privacy Policy explains how we collect, use, store and share information when operating Mana.

For any privacy-related question or request, contact:

GTM Labs SL
Trading as Mana
Email: ruben@managtm.com

2. Information we collect

Customer information

When customers contact us or use Mana, we may collect:

• Name

• Business email address

• Company name

• Account and workspace information

• Information submitted through Mana

• Communications with us

• Technical, security and activity logs necessary to operate and protect the service

Public creator and content information

Mana processes publicly available information about creators, publishers, businesses and content across social media and online platforms.

Depending on the platform and the information available, this may include:

• Profile, channel or account identifiers

• Names, usernames and handles

• Profile or channel descriptions

• Public profile URLs

• Profile images and content thumbnails

• Public country or language information

• Public follower or subscriber counts

• Public view, like, comment and engagement counts

• Content titles, descriptions, captions and tags

• Content publication dates

• Content duration and format

• Public categories or topics

• Other public information provided by the relevant platform or authorised data source

The platforms we may process information from include YouTube, Instagram, TikTok and other social media, video, publishing and creator platforms.

We do not collect or store users’ passwords or login credentials for these platforms.

Unless clearly stated as part of an optional authorised integration, we do not access private social-media account information.

Proprietary analysis

We use our own systems, including automated and artificial-intelligence systems, to create additional insights from public creator and content information.

These insights may include:

• Main creator or content category

• Subcategories

• Content topics

• Content formats

• Geographic focus

• Posting frequency

• Average and median performance

• Engagement metrics

• Content consistency

• Brand suitability

• Creator-to-brand affinity

• Confidence scores

• Supporting evidence and explanations

These classifications, scores and metrics are created by Mana. They are not official classifications, recommendations, measurements or endorsements provided by any social platform.

3. Social platforms and third-party services

Mana may access public information through official APIs, authorised integrations, licensed data providers or other methods permitted by the relevant platform and applicable law.

Our use of information from each social platform is subject to that platform’s applicable:

• Terms of service

• Developer terms

• API policies

• Data-use requirements

• Privacy requirements

• Branding requirements

• Retention and deletion rules

We apply these requirements separately to information obtained from each platform.

This means that information originating from YouTube is handled according to YouTube’s requirements, information originating from Meta or Instagram is handled according to Meta’s requirements, and information originating from TikTok is handled according to TikTok’s requirements.

Where a platform requires information to be refreshed, restricted or deleted within a particular period, we apply the relevant platform-specific period.

Mana is an independent service. We are not owned, operated, sponsored or endorsed by YouTube, Google, Meta, Instagram, TikTok or any other social platform unless explicitly stated otherwise.

YouTube

Mana uses YouTube API Services to access public information about YouTube channels and videos.

Use of YouTube-related functionality is also subject to the YouTube Terms of Service.

Information about how Google processes personal information is available in the Google Privacy Policy.

YouTube API Data is refreshed or deleted according to YouTube’s applicable retention requirements, generally within 30 calendar days unless YouTube has expressly approved a different retention period for the relevant data and use case.

4. How we use information

We use information to:

• Provide and operate Mana

• Create and manage customer accounts

• Help customers discover creators

• Organise creator information

• Classify creators and content

• Calculate performance metrics

• Evaluate creator-to-brand relevance

• Support creator, influencer and affiliate marketing

• Improve our classifications, models and service functionality

• Respond to questions and support requests

• Detect fraud, misuse and unauthorised access

• Comply with legal, contractual and platform-specific obligations

Mana’s analysis is intended to help customers research and evaluate potential commercial partnerships.

Customers remain responsible for reviewing the available information and making their own campaign, outreach, contractual and commercial decisions.

5. Legal basis for processing

Where European data-protection law applies, we process customer information where necessary to provide our service and fulfil our contractual obligations.

We generally process public professional creator information based on our legitimate interest in operating a B2B creator intelligence and campaign-planning service.

When relying on legitimate interests, we consider:

• The public and professional nature of the information

• The likely expectations of the person concerned

• The purposes for which the information is used

• The potential impact of the processing

• The person’s ability to request access, correction or deletion

We may also process information where required by law or where the relevant person has provided consent.

6. Automated analysis

Mana uses automated systems to classify and analyse creators and their content.

Automated results:

• Are estimates based on the available information

• May be incomplete or inaccurate

• May change when the source information changes

• May change when our models or taxonomy change

• Are not provided or approved by the original social platform

• Should be reviewed before making important decisions

We do not intentionally use social-platform information to infer sensitive characteristics such as ethnicity, religion, political opinions, health conditions or sexual orientation.

7. How we share information

Creator information and Mana’s proprietary analysis may be made available to customers using the Mana platform.

We do not sell raw social-platform data as a standalone database, data feed or substitute for the original platform or its API.

Customers pay for access to Mana’s software, creator discovery functionality, organisation of information, classifications, calculated metrics and proprietary analysis.

We may share information with service providers that help us operate Mana, including providers of:

• Cloud infrastructure

• Database hosting

• Artificial-intelligence services

• Security and monitoring

• Email and customer support

• Legal and accounting services

These providers may only process information as necessary to provide their services to us and must protect it appropriately.

We may also disclose information where required by law or where necessary to protect Mana, our customers, creators or other persons.

8. Data retention

We retain information only for as long as necessary for the purposes described in this Privacy Policy and as permitted by applicable law.

Information originating from a social platform is retained, refreshed or deleted according to the requirements that apply to that specific platform.

Where a profile, channel, account or item of content is deleted, made unavailable or materially changed, we will update or remove the corresponding information where required.

Mana’s proprietary classifications and calculated metrics are retained only for as long as permitted by applicable law and by the requirements of the source platform.

Customer, contractual and business records may be retained for as long as necessary to provide the service, comply with legal obligations and resolve disputes.

9. Cookies

Mana does not currently use cookies, advertising pixels or similar tracking technologies.

We may still collect limited technical and security logs that are necessary to operate the service, protect accounts and investigate errors or unauthorised activity.

If we introduce cookies or similar technologies in the future, we will update this Privacy Policy and request consent where required by law.

10. Your rights

Depending on your location, you may have the right to:

• Request access to personal information we hold about you

• Request correction of inaccurate information

• Request deletion of your information

• Request restriction of processing

• Object to processing based on legitimate interests

• Withdraw consent where processing is based on consent

• Submit a complaint to a data-protection authority

Creators may contact us to request access to, correction of or deletion of information associated with their Mana profile.

To help us identify the relevant information, please include the applicable profile, channel or account URL.

Requests should be sent to:

ruben@managtm.com

We may request reasonable information to verify the identity and authority of the requester.

Deleting information from Mana does not delete or modify the original information on the social platform. Changes to the original account or content must normally be made through the relevant platform.

11. Data security

We use reasonable technical and organisational measures to protect information against:

• Unauthorised access

• Accidental loss

• Unlawful disclosure

• Alteration

• Destruction

• Misuse

These measures may include access controls, authentication, encryption in transit, monitoring, backups and restricted access to production systems.

No online system can guarantee absolute security.

12. International processing

Some of our service providers may process information outside Spain or the European Economic Area.

Where required, we use appropriate safeguards for international transfers, such as adequacy decisions or Standard Contractual Clauses.

13. Children

Mana is a business service and is not intended for use by children.

We do not knowingly allow children to create customer accounts.

14. Changes to this Privacy Policy

We may update this Privacy Policy when our service, data practices, legal obligations or use of third-party platforms changes.

The latest version will be published with an updated revision date.

15. Contact

For questions, complaints or privacy requests, contact:

GTM Labs SL
Trading as Mana
Email: ruben@managtm.com