Data protection information about Social Media Listening

Komons analyzes the social conversation exclusively in social networks and other public access sources to study opinions and reactions in social networks and media on general and particular public interest issues. To do this, we analyze aggregated data in trends or “topics” and individualize the notorious users who lead them. 

What information do we process?

Personal and non-personal data made manifestly public by users themselves. We apply privacy techniques from design (data protection has been taken into account as an integral part of our analysis process) and minimization. 

We suppress identifiers and only re-identify the most notorious users. In these cases, we process the identifying and contact information published, if any, in the profile (bio or user name) and the content of what is published (date of publication, author, reach), and we measure reaction and sentiment on the topic in question.

How do we process your data?

We legitimize our processing on our legitimate interests (to analyze and better understand the social conversation, and report on it, to promote positive values, to provide our expert advice to our beneficiaries), taking into consideration data subjects’ legitimate expectations and implementing measures to protect the impact on their rights and interests. 

We study aggregate opinions, sentiment and profiling data provided by the source platforms themselves to which we contribute our expert knowledge, contextualizing it to the country, social, economic and cultural environment and to the specific subject matter. 

In accordance with our Code of Conduct, Komons does not get involved in actions or campaigns against any company or person; does not accept to be hired to develop discrediting or harassment campaigns, nor does it offer guarantee on solutions that it does not consider viable or ethical: Komons only positively promotes the client’s message.

The conversation analysis performed complies with the terms and conditions of the social networks and public access sources used for this purpose. 

Personal information will be processed for the time strictly necessary for the realization of the project, being subsequently blocked for secure deletion, or anonymized. Deliverables to customers containing personal information are retained for a maximum period of five years. 

Data transfers

Personal data may occasionally be transferred to our customers, subject to a case-by-case assessment of the circumstances of the data subject and the prior implementation of protection and limitation measures, and specific information to the data subject, where appropriate.

We use U.S. service providers, with whom standard contractual clauses have been signed (based on the 2021 model), in accordance with art. 46.2.c) GDPR.

How to object to the data processing, exercise other rights or request more information

You may contact us to request further information on this subject, or to exercise your rights of access, rectification, erasure, restriction of processing, and objection, by sending a request to the following e-mail address: 

You are also reminded of the possibility of going to the competent data protection authority to report breaches and obtain the protection of the aforementioned rights. 

January 2023