Promosphere Privacy Policy

Your privacy is important to us. This policy explains what data we collect, how we use it, and your choices.

1. Introduction

Promosphere is committed to protecting the privacy of our users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform. By accessing our services, you consent to the data practices described in this policy.

2. Information We Collect

We collect information to provide and improve our services, ensuring a secure and efficient ecosystem for influencers and brands. The types of information we collect include:

• Personal Identification Information: We collect personal details, such as your name ,contact information and government-issued identification, such as a passport or driver's license number, for identity verification purposes and registration for an account
• Social Media Data: For influencers, we access social media data through public APIs (Meta Graph API, TikTok public API, and YouTube Data API) with your consent. This data is used for our influencer eligibility system and to generate smart profiles that include reach, engagement statistics, and growth metrics.
• Transactional Data: When you use our platform for campaigns, we collect data related to deals, including transaction size, frequency, and payment information to facilitate our escrow system.
• User-Generated Content: We store user-generated content, such as campaign proposals, digital contracts, and work links.
• Technical Data: We collect information about how you interact with our platform, including usage details, IP addresses, and information related to your device and browser. This data helps us monitor and improve our technical infrastructure.

3. How We Use Your Information

We use the collected data for the following purposes:

• To Provide Services: We use your data to match business owners with influencers, facilitate communication, manage contracts, and process secure payments.
• To Ensure Trust and Transparency: The influencer eligibility system uses your social media data to ensure only credible creators are on the platform, building a trusted environment for brand collaborations.
• To Improve the Platform: We analyze usage and performance data to enhance our matchmaking engine, optimize the user experience, and refine our analytics and reporting tools.
• To Facilitate Payments: We use transactional data to operate our payment escrow system, ensuring funds are securely held and released upon contract completion.
• For Security and Compliance: We use your data to ensure security by design and to comply with legal regulations for influencer contracts and payments.

4. Data Sharing and Disclosure

We do not sell your personal data. We may share your information with third parties in the following circumstances:

• With Business Partners: We share necessary data between influencers and business owners to facilitate collaborations and enable campaign tracking and audience insights.
• With Service Providers: We use third-party services, such as public cloud providers (AWS) and payment processors (Stripe), to operate the platform. Your data is shared with these providers only to the extent necessary to perform their functions.
• For Legal Reasons: We may disclose your information if required by law or to protect our rights or the safety of our users.

5. Data Security

The security of your data is our highest priority. Our infrastructure is designed with resilience and protection at its core, leveraging a fully serverless architecture on AWS Cloud. We ensure that all data is stored in the region closest to our users, fully aligned with applicable local data protection regulations. At present, our services are hosted in Central Europe, guaranteeing that all user data remains securely stored within this jurisdiction.

6. Your Choices and Rights

Depending on your location, you may have the right to access, correct, delete, restrict, or receive a copy of your personal information, and to object to or withdraw your consent for certain processing. You can view and update most of your information directly from your account settings at any time. To exercise any right not available in-app, contact us using the details in Section 15.

Disconnecting a social media account. You may disconnect any linked Facebook, Instagram or TikTok account from Settings → Social Accounts at any time. When you do, we stop using the data we obtained from that platform and delete the connection tokens, cached profile details, and metrics we had retained from it. If you instead remove Promosphere from your Facebook or Instagram settings directly, Meta notifies us and we perform the same deletion automatically. You can check the status of a Meta-initiated deletion request at any time at /data-deletion using the confirmation code Meta provides you.

Deleting your account. You may permanently delete your Promosphere account from Settings → Delete Account. When you do:

• We disconnect and revoke access to every linked social media account, and delete the associated tokens and platform data as described above.
• We remove your profile details, portfolio, services, saved searches and other identifying information from your account and, where you were an influencer, from your public influencer profile.
• We replace your identifying account fields (name, email, phone, profile photo, and similar) with anonymized placeholders, and delete identity documents you uploaded, saved payment details such as bank account numbers and billing address, and your sign-in and verification history. We keep only the outcome of an identity verification, not the document details. Messages and dispute records that reference your account continue to display to the other party as "Deleted User" instead of being removed, so that records and evidence for the other party are not disrupted.
• Contract, invoice, payment, payout and dispute records are retained, as required for financial record-keeping, accounting, tax and legal compliance, and for the establishment, exercise or defence of legal claims by you, the other party or Promosphere. For each contract you signed, we keep the identity and contact details you had provided when you signed (name, email, phone number, address and, for a business, the company name and registration number), together with the signature date and IP address. These details appear on the contract document itself and are used only for those purposes. These records do not contain data obtained from Meta, TikTok or YouTube.
• Security and audit logs (for example account and sign-in events) are kept for security and fraud-prevention purposes for 2 years, then deleted. The history of a contract (signatures, milestones) is kept with the contract record.
• We send you a confirmation email once the deletion described above has completed.

Deletion may be delayed if you have open obligations. To protect both parties to a collaboration, we cannot delete an account that has a contract awaiting signature or in progress, an unresolved dispute, or an unpaid balance or pending payout. If this applies to you, we will tell you what needs to be resolved first when you request deletion.

7. Data Retention

We retain personal information for as long as your account is active, and for as long as needed to provide the platform, comply with our legal and tax obligations, resolve disputes, and enforce our agreements. Contract, invoice, payment, payout and dispute records are retained after account deletion, for financial record-keeping, legal compliance and legal claims, including the signing parties' identity and contact details recorded on each signed contract. Data obtained from Meta, TikTok, or YouTube is deleted or de-identified once it is no longer needed for the influencer eligibility check or metrics display it was collected for, or upon disconnection of the corresponding account, whichever happens first.

8. Cookies and Similar Technologies

We use strictly necessary cookies and similar technologies to keep you signed in, remember your preferences, and protect the platform against fraud and abuse. We do not use third-party advertising cookies. Because these cookies are required for the platform to function, they cannot be disabled from within the platform; you may block or delete cookies through your browser settings, which may affect your ability to use the platform.

9. Children's Privacy

Promosphere is intended for users who are at least 18 years old and is not directed at children. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from a user under 18, we will delete it and, if applicable, deactivate the associated account.

10. International Data Transfers

Our infrastructure is hosted in Central Europe, and your data is stored there regardless of where you access the platform from. Some of our service providers and social media partners (including Meta, TikTok, YouTube, AWS, and Stripe) may process data outside of your home country. Where this involves a transfer out of the European Economic Area, we rely on appropriate safeguards, such as standard contractual clauses, to protect your information.

11. Automated Decision-Making

Our influencer eligibility system uses automated checks against social media metrics, such as follower count and engagement, to help determine whether an influencer profile meets the platform's minimum credibility standards. This check supports, but does not replace, human review of flagged or borderline cases, and you may contact us to request a manual review of an eligibility decision.

12. Meta Platform Data

Where we access information through Meta's Graph API (Facebook and Instagram), we use it only for the purposes disclosed in this policy: identity and eligibility verification, and displaying reach and engagement metrics to business owners. We do not sell Meta Platform Data, and we do not use it for advertising. Meta Platform Data is deleted or de-identified when you disconnect the corresponding account, delete your Promosphere account, or remove Promosphere's access from your Facebook or Instagram settings, as described in Section 6.

13. Data Breach Notification

If we become aware of a security incident that compromises your personal information in a way that requires notice under applicable law, we will notify you and the relevant authorities within the timeframes required by that law.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "last updated" date at the top of the policy. Your continued use of the platform after any changes constitutes your acceptance of the new terms.

15. Contact Us

If you have questions about this Privacy Policy or wish to exercise a privacy right described above, contact us at support@promospherecenter.com.