Relationship between Xeerpa, the Client and the Users

What’s the relation between Xeerpa and its client?

Xeerpa provides a service to the Client (your company) whereby the data from the Client’s end users will be analyzed. This data will become part of one or more files, which ownership and responsibility will be the Client’s. By accepting the terms and conditions published by the Client in its website, mobile app, wi-fi portal or promotion, together with the own terms and conditions and privacy policies published by the social network used by the end user, the Client’s users (the end users) authorize the Client the usage of their data.

Xeerpa will provide certain services which will allow to gather, store and analyze the information containing the personal details from the users.

The client is owner and Responsible for these files containing the data (the “File”) and Xeerpa acts solely as a service provider, providing data treatment. This implies:

  • Xeerpa is not the owner of the Files.

  • Xeerpa will not be allowed to use the information of the users to contact them.

  • Xeerpa will not be allowed to sell or give away data to third party entities without the Client’s approval.

  • Xeerpa will treat the data to make them more accessible and useful, for the Client to use under its responsibility and under the guidelines of the current legislation.

  • Each Client of Xeerpa has a separate Database and therefore it is not possible to cross the data from different Clients, nor get access to different Client’s data of users.

Xeerpa keeps the right of using the anonymized users’ data of its Clients to perform analysis, comparatives and benchmarking. These analysis and comparatives do not contain perdonsl data and therefore:

  • The personal details of the users are made anonymous in an irreversible way.

  • The Client owner and the original promotion source of the users’ data are anonymous and irreversible.


Is there any change in the relationship between the user and the Client using Xeerpa?

No, the client must keep informing its users the same way, as per the laws guidelines: it will ask permission to the users to gather the data from the Social Networks and will inform them about how that data is going to be used and what treatments it will receive, in the same way it would if the data were handed by the users through a form, telephone, etc.

The Xeerpa service runs in the background completely transparent for the end users and therefore the Xeerpa service may not be known to them.

The Client will need to register the File containing user data as required by its regional Data Protection Laws applicable. For instance in the EU, the File will need to be registered at the Data Protection Agency with a classification of HIGH if it includes posts, tweets or comments made by the user, or as MEDIUM if it just contains Likes, basic profile information such as age, name or email, geo-locations, etc.

How does Xeerpa recommend how to inform users about the usage their data will receive?

Xeerpa has a Data Protection Policy template available for the Clients, which can be modified if necessary and used in websites, apps for mobile devices, promotions or Wi-Fi hotspots.

Should the Client want to get in contact with the users through marketing campaigns, the Client must show an opt-in box for the user to accept that possibility.