Moon at Dawn Ltd
Privacy Notice
Version 1.1 | Effective date: 29 May 2026 | Next review: May 2027
This notice explains how Moon at Dawn Ltd collects, uses, and stores personal data, and what rights you have in relation to that data. We handle personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Who we are
Moon at Dawn Ltd is a B2B influencer intelligence business registered in England and Wales (Companies House No. 16611776). We help marketing teams identify, evaluate, and engage professional content creators and subject matter experts.
Our appointed Data Protection Officer is Will Beech, contactable at will.beech@moonatdawn.com.
What data we process and why
1. Professional profile data (B2B influencers)
In delivering our service, we analyse publicly available professional personal data relating to individuals who publish content in a professional capacity. This includes:
• Full name
• Job title and employer
• Professional biography
• Publicly posted professional content and associated engagement metrics
This data is sourced from publicly available professional platforms and directories. We do not process financial data or data relating to individuals in their personal lives.
As part of our brand safety and vetting process, we conduct web searches of publicly available information to identify whether an individual has been publicly associated with controversy or reputational risk. This may incidentally surface information that touches on restricted data categories under UK GDPR — such as references to criminal proceedings or public conduct relating to sensitive topics. This information is not collected or stored in our systems. It is reviewed by a human assessor solely to produce a brand safety flag, and no determination is made on the basis of automated processing alone. The check is a conduct and reputation assessment based on public domain information, not a categorisation of any personal characteristic.
2. Engager data
As part of our audience analysis, we process pseudonymised data relating to individuals who engage with influencer content. This includes job title, employer, and engagement activity. Engagers are assigned a reference number as a pseudonymised identifier to enable accurate de-duplication across content. This reference number is not linked to a name or any directly identifiable information in our systems.
3. Client and contact data
We process contact information for individuals at our client organisations to manage business relationships and deliver our services. This includes names, job titles, email addresses, and telephone numbers.
Our lawful basis for processing
For professional profile data, our lawful basis is legitimate interests under Article 6(1)(f) of the UK GDPR. We have conducted a Legitimate Interests Assessment and are satisfied that our interests are not overridden by the rights of the individuals concerned, given that:
• All data is publicly available and was made public by individuals in a professional context
• Processing is limited to professional information only
• The privacy impact on individuals is low
• Individuals can opt out at any time
Where our brand safety process incidentally surfaces publicly available information relating to criminal proceedings or other sensitive matters, this is handled under the substantial public interest condition and our legitimate interests basis. Such information is reviewed by a human assessor, is not stored in our systems, and is used solely to inform a brand safety determination.
For client and contact data, our lawful basis is legitimate interests and, where applicable, contract.
How we use the data
Professional profile data is used solely to produce influencer scoring reports and recommendations for our clients. We do not sell personal data, share it with unauthorised third parties, or use it for any purpose beyond delivery of our service.
Creators identified through client engagements may be added to our wider intelligence database for the purpose of improving the quality of our service. Dentsu-specific outputs, campaign weightings, ICP criteria, and strategic information are not shared with any other client and remain confidential to the relevant engagement.
Who we share data with
We share outputs — in the form of reports and recommendations — with our clients as part of service delivery. We do not transfer raw personal data to third parties.
We use Supabase as our database and infrastructure provider. Supabase processes data on our behalf as a data processor and is bound by appropriate data processing terms.
International transfers
Where any data is processed outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR requirements.
How long we keep data
We retain professional profile data only for as long as it is needed to deliver our services. Client contact data is retained for the duration of the business relationship and for a reasonable period thereafter for legal and administrative purposes. Brand safety information surfaced during vetting is not retained beyond the point of human review.
Your rights
Under UK GDPR, you have the right to:
• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data
• Object to our processing of your data
• Request restriction of processing
To exercise any of these rights, contact our DPO at will.beech@moonatdawn.com. We will respond within one calendar month.
Right to complain
If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.
Changes to this notice
We review this notice annually. Any material changes will be reflected in an updated version with a revised effective date.
Moon at Dawn Ltd | Companies House No. 16611776 | Registered in England and Wales