Privacy Policy

1. Introduction

1.1 This Privacy Policy explains how Social Kit, Inc. d/b/a Creally ("Creally", "we", "us", or "our") collects, uses, discloses, and otherwise processes personal data when operating the website located at https://www.creally.io/ and any related software, hosted applications, tools, interfaces, databases, workflows, automations, content, and services made available through the platform (collectively, the "Platform" or "Services").

1.2 This Privacy Policy applies to personal data that Creally processes as a controller in relation to two categories of individuals ("you"): Users — individuals acting on behalf of Creally’s Customers or prospective Customers, including account users, administrators, team members, and business contacts; and Creators — individuals whose profiles, content, contact details, audience-related information, or other professional or public-facing information may be processed through the Platform, including creators who interact with the Platform directly and creators whose information is collected from public or other lawful sources.

1.3 This Privacy Policy supplements the Terms of Service. Capitalized terms not defined in this Privacy Policy have the meanings given to them in the Terms of Service.

1.4 For clarity, where Creally processes personal data solely on behalf of a Customer in connection with Customer-controlled use of the Services, Creally acts as a processor or service provider, not as an independent controller. Such processing is governed by the Terms of Service, the applicable Data Processing Addendum (available at https://www.creally.io/dpa), and the Customer’s own privacy disclosures.

2. Who is the data controller?

The data controller for the processing described in this Privacy Policy is: Social Kit, Inc. d/b/a Creally, 2261 Market Street STE 74683, San Francisco, CA 94114, United States. Email: [email protected].

3. Categories of personal data Creally processes

Depending on the relevant relationship and use of the Platform, Creally may process the following categories of personal data.

3.1 Users. For Users, Creally may process:

• Identification data*: name, first name, username, and, if applicable, a photo.
• Professional data: work email, work phone number, job title, and employer (Client).
• Connection data*: browsing data (cookies) and IP address.
• Any other information that the User transmits via the Platform.

3.2 Creators. For Creators, Creally may process:

• Identification data*: name, first name, date of birth, nickname/alias, age, nationality, contact details, photos, videos, sound, and physical description if applicable.
• Personal life data*: social networks and/or sites used, posts made on social networks, lifestyle habits.
• Professional life data* : CV, services provided, business registration number, profession, VAT number, legal representative identity, and mission details for clients.
• Financial data: remuneration and/or estimated revenue for partnerships and, where the payout feature is used, payout amounts, payout status and the payout method type selected by the Creator .
• Connection data*: browsing data (cookies) and IP address.
• Social login data: if Creators log into their account from a social media platform (such as Instagram, TikTok, or Twitter), that platform may disclose the Creator’s profile data and any information the Creator has authorized to be shared.

3.3 The personal data identified by an asterisk (*) is mandatory for the use of the Platform. Where a Creator is designated only as the recipient of a payout, Creally processes only the Creator's email address and the payout data described in Section 5.3.

3.4 Users and Creators are required to provide accurate, truthful, and up-to-date information when providing data to Creally.

3.5 Creally collects personal data either directly from Users and Creators (via forms, communications, or exchanges) or indirectly from third parties (Customers, websites, social networks, third-party cookies, etc.), including from public sources such as public websites, creator platforms, and public social media pages.

3.6 Creally does not require Creators or Users to provide sensitive personal data for the normal use of the Platform, and Creally asks that such data not be submitted unless strictly necessary and lawful.

4. Purposes of processing and legal bases

Creally processes personal data for the following purposes and, where GDPR applies, on the following legal bases.

4.1 Users

4.2 Creators

4.3 Where Creally relies on legitimate interests, those interests generally include operating and improving the Platform, enabling efficient creator discovery and relationship workflows, maintaining accurate and useful business data, ensuring security, and running our business responsibly and effectively. Creally balances these interests against the rights and freedoms of the individuals concerned, and Creators may object to processing based on legitimate interests at any time as described in Section 9.

4.4 Where required by law, Creally will rely on consent, including for certain cookies and similar technologies.

5. Disclosures of personal data

5.1 Creally may disclose personal data to the following categories of recipients, as necessary for the purposes described above:

• our affiliates and corporate group entities, where relevant;
• hosting, infrastructure, security, analytics, communication, support, CRM, payment, and other service providers;
• third-party integration partners and platform providers, where a User or Customer chooses to enable such integrations;
• professional advisers, auditors, insurers, and legal counsel;
• our payment provider, where a Customer enables the payout feature, which acts as an independent controller and not as a service provider (see 5.3);
• competent courts, regulators, public authorities, tax authorities, law enforcement, or other third parties where required by law or necessary to protect our rights or the rights of others;
• parties involved in a corporate transaction, such as a merger, acquisition, financing, reorganization, or sale of assets; and
• in the case of Platform interactions, Users and Creators may receive certain information about one another where this is inherent to the relevant functionality or communication flow.

5.2 Where Users connect Google services or other third-party accounts, the use of data received through such integrations is also subject to the relevant third-party provider rules and policies.

5.3 Creally offers an optional payout feature that allows a Customer to instruct a payment to a Creator. Creally does not process payments and does not hold funds. Where the feature is enabled, Creally shares personal data with, and receives personal data from, the payment provider identified below. The payment provider acts as an independent controller and processes that data under its own privacy notice. Creally does not control and is not responsible for that processing.

5.4 Creally’s legal basis for sharing and receiving this data is its legitimate interest in providing the payout feature requested by the Customer and, in respect of Users, performance of a contract. Personal data shared with the payment provider is transferred to Switzerland, which the European Commission has recognized as providing an adequate level of protection.

5.5 Where a Customer designates a Creator as the recipient of a payout, Creally discloses to the payment provider the Creator's email address, together with the amount and currency of the payout and the description of the work entered by the Customer, so that the payment provider can invite the Creator to set up the payout and verify the Creator's identity. The payment provider processes verification and payout data as an independent controller under its own privacy notice, and requests concerning data the payment provider collects directly should be addressed to it. Creators may contact Creally at [email protected] with questions about this disclosure or to exercise the rights described in Section 9. An objection does not affect a payout that has already been instructed.

6. International transfers

6.1 Creally is based in the United States, and personal data covered by this Privacy Policy may be processed in the United States and in other countries where Creally or its service providers operate.

6.2 Where GDPR applies and personal data is transferred outside the EEA, the UK, or Switzerland, Creally will use appropriate transfer mechanisms as required by applicable law, which may include adequacy decisions, standard contractual clauses, or other lawful transfer mechanisms recognized under applicable data protection law.

6.3 You acknowledge that countries outside the EEA may not provide the same level of data protection as your home jurisdiction, but Creally takes measures designed to ensure that personal data remains protected in accordance with applicable law.

7. Data retention

7.1 Creally retains personal data for as long as necessary for the purposes described in this Privacy Policy, including for the duration of the relevant account, Customer relationship, creator profile lifecycle, or business relationship.

7.2 After that, Creally may retain personal data for a limited period as necessary to: comply with legal, tax, accounting, audit, or regulatory obligations; maintain appropriate business records; resolve disputes; enforce our agreements; or establish, exercise, or defend legal claims.

7.3 Unless a longer period is required or justified, Creally generally retains relevant business records and related data for up to five (5) years after the end of the relevant relationship or activity, with restricted access where appropriate.

8. Data security

8.1 Creally uses administrative, technical, and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access.

8.2 These measures may include access controls, authentication safeguards, logging, monitoring, encryption or equivalent protections where appropriate, internal policies, incident response processes, and vendor oversight measures.

8.3 No method of transmission or storage is completely secure, and Creally cannot guarantee absolute security.

9. Your rights

9.1 Where GDPR or similar laws apply, Users and Creators may have the right to: request access to their personal data; request correction of inaccurate or incomplete personal data; request deletion of personal data; request restriction of processing; object to processing carried out on the basis of legitimate interests; request data portability, where applicable; withdraw consent at any time, where processing is based on consent; and lodge a complaint with a competent supervisory authority.

9.2 To exercise these rights, please contact Creally at [email protected]. Creators may also request removal of their profile from the Platform through the same address.

9.3 Creally may request information necessary to verify your identity and process your request. Creally may also decline or limit requests where permitted by applicable law.

10. Cookies and similar technologies

10.1 Creally uses cookies and similar technologies to operate the website, remember preferences, analyze traffic, improve performance, and, where permitted, support communications and marketing.

10.2 Where required by law, Creally will request consent before placing non-essential cookies or similar technologies on your device. You can manage cookie preferences through the cookie banner or your browser settings.

10.3 Further detail is set out in Creally’s Cookie Policy, available on the website.

11. Third-party websites and services

The Platform may link to or interact with third-party websites, platforms, integrations, or services. Creally is not responsible for the privacy practices of those third parties. Creally encourages Users and Creators to review the privacy notices of any third-party services they use or interact with.

12. Children

The Platform is intended for business and professional use and is not directed to children. Creally does not knowingly collect personal data from children in connection with the ordinary operation of the Platform. If you believe that personal data relating to a child has been provided to Creally unlawfully, please contact us.

13. Changes to this Privacy Policy

13.1 Creally may update this Privacy Policy from time to time, including to reflect changes in the law, the Platform, our data practices, or our business operations.

13.2 If Creally makes material changes, Creally will post the updated version on the Platform and may provide additional notice where appropriate. The "Last modified" date at the top of this Privacy Policy indicates when it was last revised.

14. Contact us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact: Social Kit, Inc. d/b/a Creally, 2261 Market Street STE 74683, San Francisco, CA 94114, United States. Email: [email protected].

CALIFORNIA PRIVACY ADDENDUM

Last modified: September 2, 2026

This California Privacy Addendum (the "California Addendum") supplements the Privacy Policy of Social Kit, Inc. d/b/a Creally ("Creally") and applies solely to individuals who are residents of the State of California.

This California Addendum is intended to provide additional disclosures under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the "CCPA"). It describes how Creally collects, uses, discloses, and otherwise processes Personal Information relating to California residents in connection with its website, platform, and related services. Capitalized terms not defined in this California Addendum have the meanings given to them in the Privacy Policy or the Terms of Service, as applicable.

1. Scope

This California Addendum applies to Personal Information that Creally collects and processes about California residents in its capacity as a business under the CCPA. It does not apply to Personal Information that Creally processes solely on behalf of its business Customers as a service provider or contractor, where the relevant Customer determines the purposes and means of processing. That processing is governed by Creally’s agreements with the relevant Customer and the Customer’s own privacy notices.

2. Categories of Personal Information Creally Collects

In the preceding twelve (12) months, depending on the nature of the relationship with Creally and the use of the Services, Creally may have collected the following categories of Personal Information about California residents.

2.1 Users: identification data (name, first name, username, and, if applicable, a photo); professional data (work email, work phone number, job title, and employer); connection data (browsing data (cookies) and IP address); and any other information that the User transmits via the Platform.

2.2 Creators: identification data (name, first name, date of birth, nickname/alias, age, nationality, contact details, photos, videos, sound, and physical description if applicable); personal life data (social networks and/or sites used, posts made on social networks, lifestyle habits); professional life data (CV, services provided, business registration number, profession, VAT number, legal representative identity, and mission details for clients); financial data (remuneration and/or estimated revenue for partnerships and, where the payout feature is used, payout amounts, payout status, and the payout method type selected by the Creator); connection data (browsing data (cookies) and IP address); and social login data (where Creators log into an account from a social media platform, that platform may disclose the Creator’s profile data and any information the Creator has authorized to be shared).

2.3 For the avoidance of doubt, this California Addendum does not expand the categories of Personal Information processed by Creally beyond those described in the Privacy Policy.

3. Sources of Personal Information

Creally may collect Personal Information from the following categories of sources: directly from Users and Creators; from Customers and their authorized users; from public sources, including public websites, creator platforms, and public social media pages; from social media platforms where a Creator uses social login functionality; from third-party integrations and service providers; from communications sent to Creally; and automatically through cookies, analytics tools, logs, and similar technologies.

4. Business and Commercial Purposes for Collection, Use, and Disclosure

Creally may collect, use, retain, disclose, or otherwise process Personal Information for the following business or commercial purposes: providing, operating, maintaining, supporting, and securing the website, Platform, and Services; creating and managing accounts, subscriptions, and access permissions; providing creator discovery, CRM, analytics, outreach-related workflows, AI-enabled functionality, support, and related features; communicating with Users, Creators, Customers, and prospective Customers; troubleshooting, debugging, performance monitoring, quality assurance, fraud prevention, abuse prevention, incident detection, and internal logging; improving, developing, testing, and optimizing the Services and internal operations; billing, renewals, financial administration, and account management; complying with legal, regulatory, tax, accounting, audit, and enforcement obligations; and establishing, exercising, or defending legal claims and protecting rights, property, and safety.

5. Categories of Third Parties to Whom Creally Discloses Personal Information

Creally may disclose Personal Information to the following categories of third parties: hosting, cloud, infrastructure, analytics, communications, support, security, payment, and other service providers; integration partners and platform providers where a User, Creator, or Customer chooses to enable such integrations; payment service partners, where relevant to creator-related payments or related financial flows; professional advisers, auditors, insurers, and legal counsel; courts, regulators, law enforcement, public authorities, and governmental bodies where required by law or necessary to protect rights and interests; parties involved in an actual or contemplated corporate transaction; and Users and Creators, where disclosure is inherent to the relevant Platform functionality or communication flow.

6. Sale or Sharing of Personal Information

Creally does not sell Personal Information for monetary consideration. However, certain uses of cookies, pixels, tags, analytics, or advertising technologies on Creally’s website may constitute "sharing" or "selling" of Personal Information under the CCPA, including where information is made available to third parties for cross-context behavioral advertising. In such cases, California residents have the right to opt out of such sale or sharing, including through an opt-out preference signal where required by law. Creally does not knowingly sell or share the Personal Information of consumers under 16 years of age.

7. Sensitive Personal Information

To the extent any Personal Information listed in this California Addendum qualifies as Sensitive Personal Information under the CCPA, Creally does not use or disclose such Sensitive Personal Information for purposes other than those permitted by the CCPA, including providing the Services, ensuring security and integrity, performing services on behalf of the business, detecting and preventing incidents, resisting malicious or unlawful actions, maintaining quality and safety, short-term transient use, and other permitted internal business purposes. To the extent Creally uses or discloses Sensitive Personal Information beyond those permitted purposes, California residents may have the right to request that Creally limit such use or disclosure.

8. Retention

Creally retains Personal Information for as long as reasonably necessary and proportionate to achieve the purposes for which it was collected or processed, including to provide the Services, maintain business records, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods may vary depending on the nature of the relationship, the category of Personal Information, operational necessity, legal obligations, and risk considerations. Additional detail is set out in the Privacy Policy.

9. California Privacy Rights

If you are a California resident, you may have the following rights, subject to certain exceptions and verification requirements: the right to know the categories of Personal Information Creally has collected about you, the categories of sources, the business or commercial purposes for collecting, selling, or sharing that information, the categories of third parties to whom it was disclosed, and the specific pieces of Personal Information Creally has collected about you; the right to delete Personal Information that Creally collected from you; the right to correct inaccurate Personal Information that Creally maintains about you; the right to opt out of the sale or sharing of your Personal Information; the right to limit the use and disclosure of your Sensitive Personal Information, where applicable; the right not to receive discriminatory treatment for exercising your privacy rights; and the right to designate an authorized agent to submit certain requests on your behalf.

10. How to Exercise Your Rights

California residents may submit requests to exercise their privacy rights by contacting Creally at [email protected]. Creally may need to verify your identity before processing your request. Depending on the nature of the request, Creally may ask you to provide information sufficient to verify that you are the person about whom Creally collected Personal Information or that your authorized agent is validly authorized to act on your behalf. Authorized agents may submit requests on behalf of California residents where permitted by the CCPA. Creally may require proof of authorization and may also require the relevant consumer to verify their identity directly with Creally.

11. Opt-Out Preference Signals

Where required by applicable California law, Creally will process an opt-out preference signal as a valid request to opt out of the sale and/or sharing of Personal Information for the browser or device, and in some cases for the consumer, in accordance with applicable law and Creally’s technical capabilities.

12. Changes to This California Addendum

Creally may update this California Addendum from time to time. If Creally makes material changes, the updated version will be posted on the website or Platform, and additional notice may be provided where appropriate. The "Last modified" date at the top of this California Addendum indicates when it was last revised.

13. Contact Us

If you have questions about this California Addendum or wish to exercise your California privacy rights, please contact: Social Kit, Inc. d/b/a Creally, 2261 Market Street STE 74683, San Francisco, CA 94114, United States. Email: [email protected].