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Privacy Policy

Last updated January 6, 2026

This Privacy Policy informs users and creators about personal data processing by Creally. The policy supplements the Platform’s Terms of Service, and all capitalized undefined terms reference the TOS.

Users and creators are bound by this policy upon platform use. Creally may modify it at any time with updates posted on the Platform. Modifications requiring consent will prompt reconfirmation from users.

Data Controller

Social Kit, Inc (Delaware LLC) manages personal data collection and processing:

  • Address: 2261 Market Street STE 74683, San Francisco, CA 94114, United States
  • Registered with the Delaware Commercial Register

Personal Data Processing Activities

Creally collects and processes data per GDPR (EU Regulation 2016/679) and applicable data protection laws. Processing occurs for the following purposes:

  • Account creation (Creators/Users) — Legal basis: TOS
  • Creator database creation — Legal basis: Legitimate interest
  • Creator profile management and influence measurement — Legal basis: TOS
  • User–Creator communication and campaign management — Legal basis: TOS
  • Creator research and campaign performance measurement — Legal basis: TOS
  • Customer invoicing — Legal basis: GTC and contract
  • Platform improvement via feedback — Legal basis: Legitimate interest
  • Audience measurement and content analysis — Legal basis: Legitimate interest
  • Commercial relationship management — Legal basis: Contract / legitimate interest
  • Creator payment organization — Legal basis: Contract
  • Data anonymization for market analysis — Legal basis: Legitimate interest
  • Content violation response — Legal basis: Legal obligation
  • Creator database removal — Legal basis: TOS

Data Categories

For Creators

  • Identification data*: name, first name, date of birth, nickname, age, nationality, contact details, photos, videos, sound, physical description
  • Personal life data*: social networks, posts, lifestyle habits
  • Professional data*: CV, services, business registration, VAT number, legal representative identity, mission details
  • Financial data: compensation/estimated revenue
  • Connection data*: browsing data (cookies), IP address
  • Social login data: profile information from platforms (Instagram, TikTok, Twitter, etc.)

For Users

  • Identification data*: name, first name, username, photo
  • Professional data: work email, phone, job title, employer
  • Connection data*: browsing data (cookies), IP address
  • Other information transmitted via the Platform

(* Mandatory for Platform use)

Users and creators must provide accurate, truthful, and current information.

Legal Bases for Processing

  • Performance of contract (TOS and subscription terms)
  • Legal obligations
  • Legitimate interests
  • Consent (for cookies)

Data Retention

Personal data is retained while users and creators actively use the Platform. Post-use, data is stored for five (5) years with restricted access, or during ongoing litigation.

Data Transfers

Creally shares personal data with:

  • Users and Creators (for mutual communication)
  • Amazon Web Services: Platform hosting provider (Belgium)
  • Google Synchronization: Gmail account sync complies with the Google API Services User Data Policy
  • Payment service providers: 4dev (per its privacy policy)

Upon merger or acquisition, personal data transfers to the acquiring company with user and creator notification.

Creally ensures GDPR compliance for subcontractor data processing and implements appropriate security measures.

Data Security

Administrative, technical, and organizational measures protect personal data against accidental, unauthorized, or illegal access, disclosure, alteration, loss, or destruction. Upon data breaches, Creally limits damage, notifies relevant authorities, and informs users and creators.

User Rights

Users and creators have the right to:

  • Access, rectify, or erase personal data
  • Data portability
  • Limit processing
  • Object to processing
  • Withdraw consent (where applicable)
  • File complaints with relevant data protection authorities

Exercise rights by contacting: support@creally.io.

Cookies

Creally uses cookies to optimize user experience and analyze website performance. Users can manage their preferences via the site cookie banner.

Modifications

The policy may be modified for regulatory or legal compliance. Updated versions are posted on the platform; users are encouraged to check regularly.