Supercreator LTD

1.General

• We at SuperCreator Ltd. (the "Company", "Supercreator", "We", "Us" or "Our"), are committed to protecting your ("You", "Your" or "User”) personal data and Your privacy. This privacy policy (the “Policy”) provides You with information regarding the types of information collected, processed, and used by the Company and others on Our behalf to provide You with Our services (the “Services”) and on Our website https://supercreator.app/ (the "Website") and Our online platform comprised of a browser addon and a desktop application for provision of the Services (the "Platform").
  
  Supercreator provides Services for independent content creators and for agencies representing content creators (collectively "Customers"), who may employ others and provide them with credentials to use the Platform under the license provided to them (the "Users"). As part of our Services, our Platform provides Customers certain information to assist optimizing, controlling, monetizing, and scaling engagement with relevant profiles or accounts in certain social media platforms, such as ‘OnlyFans’ platform, to which the Customers have permissions and access to ("Creator Profiles").  
  

2. The Scope

This policy explains what personal information we collect from individuals, and how we use it, keep it safe, and share it (if necessary).

This Policy is part of and should be read in conjunction with our Terms and Conditions https://supercreator.app/app-term.

In this Policy, “Personal Data” refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to.
In this Policy, the “processing” of Personal Data refers to any operation or set of operations performed on Personal Data, including the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.

3.When do We collect information about You?

• 3.1 We may collect Personal Data about You in the following circumstances:
  
  i When You visit Our Website;
  ii When You register as a user and use Our Services;
  iii When You register Your company as a user of our Services;
  iv  When You access or use the Platform as a User;
  v When You connect a Creator Profile or Your Creator Profile is connected to our Platform;
  vi When the Customers provide Personal Data to Us;
  vii When You Share Personal Data with Us to use our Services; and
  viii When You interact with Us in any manner, including by sending Us messages through third-party messaging applications, and through Our Website.
  
  3.2 You are not obligated to provide Us with any Personal Data about You. However, in some instances, not providing such Personal Data will prevent Us from providing You with the Services You and the Customers requested Us to provide and will prevent Your use of the Services or a part thereof.
  
  3.3 When You provide Us with any type of Personal Data during Your use of Our Services, You are responsible for making sure You have the all authorization and permission legally required to share this Personal Data with Us.
  

4. What types of information do We collect?

We may collect the following types of Personal Data about You:

When you are a Customer or User

4.1 Registration information and personal data – upon creation of an account with Us, You provide Us with certain information, including Your full name, email address, age, Contact information, Customer name and address, position with the Customer, as well as any other information the We may deem necessary to collect at the point of registration.

4.2 Communication information - When you contact Us, through any channel whatsoever, including social media networks, You may provide Us with Your name, certain contact information (such as email address and phone), and the content of Your communication with Us.

4.3 Information we receive from third-party platforms – to provide You with the services we receive information from third-party Platforms. The information we receive is collected by such third parties and shared with Us under their respective privacy policy, or by You directly.

4.4 Platform usage information - This information includes online activity log, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, operating system information, Your device information, crash reports and type of browser used, information regarding the device You used, including the hardware model, operating system and version, the website You visited before entering our Platform and other device identifiers). Some of this information may not identify You personally and therefore does not constitute Personal Data.

4.5 Platform activity information - Whenever You use the Platform, We monitor Your use of the Services and record Your activity. The information that We gather about You in this context includes any activity that You perform on the Platform, such as dates and times on which You will use the Platform, the length of time You will be using the Services on the Platform, the type of Services used, etc.

4.6 Creator Profiles information – to receive the Services, the Customer provides Us with information about Creator Profiles and access to these profiles. This Information may include Personal Data about the Creator, information posted by the Creator on Onlyfans and other personal information accessible to the Creator.  

4.7 Use on behalf of the Customer - When You are using the Services on behalf of an organization (Your company/ the Customer), in certain circumstances, we can link the natural person using the Services to the organization on whose behalf such person created the account, and therefore, the information you provide and that We collect about you as mentioned above may constitute Personal Data about You

Aggregate Information

4.8 We may create statistical, aggregated, and anonymized data relating to our Users and Services for analytical purposes, including business development and Platform improvements. Aggregated data is derived from Personal Data and User Data but in its aggregated form it does not relate to or identify any particular client or individual or any specific user’s data. This data is used to understand our customer base and to develop, improve, and market our Platform.

Communication Information

4.9 When You contact Us, through any channel whatsoever, including Our Website, Platform or social media, you may provide Us with Your full name, business name, and e-mail address, job description, telephone number and the content of your communication with Us.

You are responsible for ensuring the accuracy of the information You provide Us (or others on Our behalf) and for making sure this information is transferred to us without violation of any applicable laws. Inaccurate information will affect Our ability to provide You with some of the Services, as well as Our ability to contact You as contemplated in this Policy.

5. The Purposes Of The Processing Of Personal Data  

• 5.1
  Your consent that the Company will process Personal Data about You for one or more specific purposes. By way of example, to send marketing materials to You. Where We rely on Your consent, You may withdraw Your consent for the purposes for which You provided Your consent at any time by sending a notice free of charge to the following email address: hello@supercreator.app.
  
  1.2 Where You withdraw Your consent for the processing of Personal Data about You, We might not be able to provide You with some or all of the Services You requested or in the form intended to be provided to You, and You will have no claim in respect of that
• 5.2
  Processing is necessary for the performance of a contract to which You are party or to take steps at Your request before entering into a contract. This refers to all the information required for us to provide You with the Services and grant You access to the Platform and the various Services offered in connection therewith.
  
  5.3 Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. By way of example, for the purpose of improving Our Services, or for the exercise or defense of legal claims.  
  
  1.3 At any time, you may approach Us by sending a notice to the email address  hello@supercreator.app in order to receive information concerning the review performed by Us. This is so you can conclude that We may process the Personal Data about you on account of such processing being necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
   
  The following list outlines the purposes for which We may process Personal Data about you and the legal basis for any such processing:
  
  
  

6.Sharing of Personal Data

• 6.1 We will not disclose Personal Data about You to third parties except as detailed in this Policy.
  6.2 We may share Personal Data about You with third parties for the following purposes:
  6.2.1 Upon Your consent or instruction;
  6.2.2 Third parties providing Us services: Storage and hosting providers, including cloud computing services and data security services; IP address information; Analysis of user experience; Support; Marketing; CRM data management; Accounting and legal services, and; Research, analytical, technical, and diagnostic services.
  6.2.3 Third parties providing Us services related to the offering of the Services, including the Platform (e.g. cloud service providers, support providers, integrated third-party platforms providers);
  6.2.4 If we will be subject to an audit or a Due diligence process.
  6.2.5 If We sell, assign, or transfer some or all of Our business or assets to a successor or acquirer, if We are acquired by or merge with a third party, or if We file for bankruptcy or become insolvent, or any other situation where Personal Data may be sold, assigned or transferred to a successor or acquirer;
  6.2.6 To protect Our rights, property, and interest or those of third parties;
  6.2.7 To fulfill Our legal or regulatory requirements or to comply with a court order.
  

7. Transfer of Personal Data abroad

7.1 Personal Data about you may be transferred to a third country (i.e. jurisdictions other than the one you reside in) or to international organizations. In such circumstances, the Company shall take appropriate safeguards to ensure the protection of Personal Data about you and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.
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7.2 If you are an EEA resident, please note that these safeguards and protection will be available if any of the following are met:
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7.2.1 The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR");
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7.2.2 The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or

7.2.3 The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
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7.3 You may request that the Company provide you with details concerning the safeguards employed by it to protect the Personal Data about you that are transferred to a third country or an international organization, by sending an email to the following address:  hello@supercreator.app.

8. Retention of Personal Data

We will retain Personal Data about You only for as long as necessary for the fulfillment of the purposes for which such Personal Data is collected. We may retain Personal Data about You for longer periods if We find it necessary to comply with legal requirements applicable to Us.

9. Marketing communications

9.1 You may allow Us to provide You with communications from Us, as well as from third parties, either in connection with the Services or in connection with other products and services.
9.2 You may opt-out from receiving communications from Us by sending a blank e-mail to Us to  hello@supercreator.app and/or by clicking on the unsubscribe link available in Our e-mails sent to You.

10. Cookies

• 10.1 We may use certain third-party services, such as analytics companies or companies delivering advertisements, which may use cookies or other technologies, and those practices and providers are subject to their own policies.
  10.2 The Cookie (which is a small text file) is installed on the device via which You visit or access the Platform. The cookies allow Us to collect information about You and Your behavior, to improve Your user experience, to remember Your preferences and settings, and to customize and offer You products and services that may interest You. Cookies are also used to collect statistics and perform analytics.
  10.3 Some of the cookies We use are session cookies, which are downloaded temporarily to Your device and last until You close Your web browser, while others are persistent cookies, which last on Your device after You cease browsing the Service and are used to help the Service remember You as a returning visitor when You return to the Service.
  10.4 The cookies We may use have been classified according to their functionality, as follows:  
  Type of Cookie :
  
  Strictly Necessary Cookies
  Purpose:
  
  
  These cookies are strictly necessary to enable you to navigate the Platform and use features you have requested. They are used to provide you with Our content, products, and services that you have requested.
  Such cookies are essential to help your device download or stream information so that you can navigate around the Platform, use its features, and return to pages you have previously visited.
  
  
  Additional Information:
  
  
  These cookies collect Personal Data about you, such as user name and last login date, and identify you as being logged in to the Platform.
  These cookies are deleted when you close your web browser (session cookies).
  
  
  
  Type of Cookie:
  
  Functionality Cookies
  Purpose:
  
  These cookies are used to recognize you when you return to the Platform and allow Us to remember your choices and preferences.
  Additional Information:
  
  
  These cookies survive the closing of your web browser, and last until their applicable expiry time.
  
  
  Type of Cookie:
  
  
  Performance Cookies
  
  
  Additional Information:
  
  These cookies collect anonymized data that is not related to an identified or identifiable natural person.
  
  These cookies collect anonymized data that is not related to an identified or identifiable natural person.
  Type of Cookie:
  
  Third Party Marketing/Targeting Cookies
  Purpose:
  
  
  These cookies are used to provide aggregated statistics in respect of the performance of the Platform and to test and improve such performance, in order to provide better user experience. In addition, they allow Us to carry out analytical functions on the Platform.  
  
  
  Additional information:
  
  Some of these cookies are provided and used by third parties.
  These cookies are valid for varying periods; some are deleted once you close your browser, while others have an indefinite validity period.  
  10.5 You can change the privacy settings in the browser that You use, delete the existing cookies, prevent the creation of cookies, or click the setting that enables You to accept or deny the creation of a cookie every time that a cookie is detected. Please see below links to instructions on how to do this in respect of some of the most popular web browsers:  
  
  1. Firefox
  2. Internet Explorer
  3. Google Chrome
  4. Safari
  
  3.2
  
  3.3 If you do so, some or all of the Service’s features and functionalities might not perform as intended.
  
  
  ONLINE TRACKING NOTICE
  AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.
  

11. Security

11.1 We have implemented suitable security policies, rules, and technical measures to protect and safeguard the Personal Data under Our control from unauthorized access, improper use or disclosure, unauthorized modification, or unlawful destruction.

11.2 Any transfer of Personal Data via the internet cannot be fully secured. Therefore, the Company cannot ensure the protection of Personal Data about you when transferred via the internet to Us.

12.Links to Other Websites  

12.1 The Platform may contain links to websites and/or applications of third parties. Other websites and applications may also reference or link to Our Platform. We do not control such websites and applications, nor the collection and/or processing of Personal Data about You by such websites and applications, and thus We are not responsible for the privacy practices.
This Policy does not apply to any actions taken via such websites and/or applications.

12.2 Whenever You access such third parties’ websites and/or applications, We recommend that You carefully review their privacy policies before using such websites and/or applications and before disclosing any Personal Data about You.

13. Children's Privacy

We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register to the Platform or the Services. If you are under 18, please do not use the Platform. No one under the age of 18 is allowed to provide any Personal Information to us.

14.  Your rights in respect of the Personal Data about You

14.1 Generally, You have the right to request that We provide You with confirmation as to whether Personal Data about You is being collected by Us, to ask to review such data, to rectify the Personal Data if applicable, and to erase the Personal Data no longer required by Us.
14.2 Please note that We may need to receive Personal Data from You to verify Your identity before allowing You to exercise Your rights.

If you are an EEA resident please read this section below:

You are entitled to the following rights in respect of the Personal Data about you. To exercise such rights, you may send a request to exercise your rights to the following email address:  hello@supercreator.app.

14.3.4 Right of access

4.3 You have the right to receive from the Company confirmation as to whether or not Personal Data about you is being processed, and, if that is the case, access to the Personal Data and the following information: (1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries outside the European Economic Area (EEA) or international organizations; (4) if possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request from the Company rectification or erasure of Personal Data or restriction of processing of Personal Data about you or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) if the Personal Data is not collected from you, any available information as to its source; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards relating to the transfer.

4.4 The Company shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee for any further copies requested by you. If you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form.

4.5 The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others. Therefore, if the request harms the rights and freedoms of others, the Company may not fulfill your request or do so in a limited manner.

14.3.2 Right to rectification

You have the right to obtain from the Company the rectification of inaccurate Personal Data about you. Taking into account the purposes of the processing, you have the right for incomplete Personal Data about you to be completed, including by means of providing a supplementary statement.

14.3.3 Right to erasure

4.7 You have the right to obtain from the Company the erasure of Personal Data about you if one of the following grounds applies: (a) the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data about you has to be erased for compliance with a legal obligation in European Union or Member State law to which the Company is subject.

4.8 This right is not applicable to the extent that the processing is necessary (a) for compliance with a legal obligation that requires processing by European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise, or defense of legal claims.

14.3.4 Right of restriction of processing

4.9 You have the right to obtain from the Company the restriction of processing of Personal Data about you if one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling the Company to verify the accuracy of the Personal Data about you; (b) the processing is unlawful and you oppose the erasure of the Personal Data about you and request the restriction of its use instead; (c) the Company no longer needs the Personal Data about you for the purposes of processing, but the Personal Data is required by you for the establishment, exercise, or defense of legal claims; (d) if the processing of Personal Data about you is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims; or (e) if the Personal Data about you is processed for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.

4.10 If the processing of Personal Data about you has been restricted following your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

14.3.4 Right to data portability

4.11 You have the right to receive the Personal Data about you, which you have provided to the Company, in a structured, commonly used, and machine-readable format, as well as the right to transmit such Personal Data to another controller, if (a) the processing is based on your consent or on a contract to which you are a party, and (b) the processing is carried out by automated means.

4.12 In exercising your right to data portability, you have the right for the Personal Data about you to be transmitted directly from the Company to another controller, where technically feasible. The exercise of your right to data portability is without prejudice to your and the Company’s rights under your right to erasure. In addition, the right to data portability shall not adversely affect the rights and freedoms of others.

14.3.6 Right to object

4.13 You have the right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by the Company or by a third party, including profiling based on such legitimate interests. In such case, We shall no longer process the Personal Data about you, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

4.14 You have the right to object at any time to the processing of Personal Data about you for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.

14.3.7 Right to withdraw consent

4.15 You have the right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by the Company or by a third party, including profiling based on such legitimate interests. In such case, We shall no longer process the Personal Data about you, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
You have the right to object at any time to the processing of Personal Data about you for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.

14.3.8 Right to lodge a complaint with a supervisory authority

4.16 You have the right to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons in relation to the processing of Personal Data within the European Union.

4.17 Your rights in respect of Personal Data about you as outlined in this section 13 may be restricted by European Union or Member State law to which the Company is subject.

14.4 We shall provide you with the information requested according to your rights outlined in this section 13 without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of your request, together with the reasons for the delay.

14.5 The information requested according to your rights outlined in this section 13 shall be provided free of charge, unless stated otherwise in this section 13. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, We may either (a) charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.

14.6 The Company may require you to provide additional information necessary to confirm your identity in order to fulfill your request according to your rights outlined in this section 13, if We have reasonable doubts concerning the identity of the natural person making the request.

15. United States

15.1 If you reside in the United States, please read below with respect to the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), and the Colorado Privacy Act (CPA)) rights you might have:

15.1.1 Right to know:
You have the right to receive the following information: What types of Personal Data collected; What are the types of sources of the Personal Data collected; To what end We collect sell or share the Personal Data; Types of third parties to whom We disclose Personal Data, if any, and; The specific pieces of Personal Data We have collected about you.

15.1.2 Right to correct:

Taking into account the nature of the Personal Data and the purposes of the processing thereof, you have the right to request that We correct inaccurate Personal Data about you.

15.1.3 Right of Erasure

You may ask Us to delete your Personal Data and direct Our service providers to do so. Please note that We may not delete your Personal Data if it is necessary to complete Our legal obligation to you to provide the Services or otherwise protect Our legal rights, comply with an existing legal obligation; or use your Personal Data, internally, in a lawful manner that is compatible with the context in which you provided the information.

15.1.4 Right to Limit Use and Disclosure of Sensitive Personal Data:
15.1.5 You have the right to request that We limit Our use or disclosure of your “sensitive personal information” that We collected from you. We may deny your limitation request if the use and/or disclosure of the information is necessary for Us to perform Our Services or provide the goods or Services as reasonably expected by an average consumer.
15.1.6 Right to Non-selling or Sharing:
15.1.7 You may ask Us to not sell your Personal Data, or share it with a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

15.1.8 Right to Non-Discrimination for the exercise of your privacy rights:

15.1.9 You have the right to not be discriminated against by Us because you exercised any of your rights under the CCPA.

15.1.10 Right to designate an authorized agent to submit CCPA requests on your behalf:

15.1.11 You may designate an authorized agent to make a request under the CCPA on your behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to Us proof that such agent has been authorized by you. We will also require that you verify your own identity, as explained below.

15.2 In order to exercise your abovementioned rights, please contact us using the following details: email:  hello@supercreator.app.

15.3 Please note that We may need to receive Personal Data from you in order to verify your identity prior to allowing you to exercise your rights.

15.4 The rights specified may not apply to you, based on your place of residence and the relevant privacy protection laws.

16.  Changes to the Policy

We may change this Policy in Our sole discretion at any time. Any revisions to this Policy will be posted as an updated version accessible via the Platform home page. We recommend that You revisit this Policy regularly to be kept apprised of any such changes.

17. Contact Us

For any queries relating to this Policy and data protection, please contact Us at  hello@supercreator.app.