Introduction.

Social Kit, Inc., a Delaware corporation operating under the brand Creally ("Creally," "we," "us," or "our"), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website creally.io and creally.co (collectively, the "Site") and use our services (the "Services").Please read this Privacy Policy carefully. By accessing or using the Site and Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the Site or use the Services.

Information You Provide to Us

We collect information you provide directly to us, including

(a) Account Information: When you register for an account, we collect your name, email address, company name, and password.

(b) Payment Information: When you make a purchase, our payment processors collect your billing address and payment card information. We do not store credit/debit card information.

(c) Communications: When you contact us, we collect the content of your messages, including any attachments such as screenshots from your analytics.

(d) Campaign Data: Information you provide when using our campaign management features.

1.2 Information We Collect Automatically

When you access or use our Services, we automatically collect certain information, including:

(a) Log Data: IP address, browser type, operating system, referring URLs, pages visited, and timestamps.

(b) Device Information: Device identifiers, device type, and mobile network information.

(c) Usage Information: Features used, actions taken, and time spent on the Services.

(d) Cookies and Similar Technologies: We use cookies, web beacons, and similar technologies to collect information about your browsing activities.

1.3 Creator Data

Our Services provide access to information about social media influencers and content creators ("Creator Data"). This data is sourced from:

(a) Publicly available information on social media platforms;

(b) Third-party data providers and APIs;

(c) Automated collection scripts and AI-powered analysis tools.Creator Data may include profile names, avatars, profile descriptions, engagement metrics, audience demographics, and publicly available contact information.

2. How We Use Your Information

We use the information we collect for the following purposes:

(a) To provide, maintain, and improve our Services;

(b) To process transactions and send related information;

(c) To send you technical notices, updates, security alerts, and administrative messages;

(d) To respond to your comments, questions, and requests;

(e) To monitor and analyze trends, usage, and activities in connection with our Services;

(f) To detect, investigate, and prevent fraudulent transactions and other illegal activities;

(g) To personalize and improve your experience;

(h) To comply with legal obligations.

3. Legal Basis for Processing (GDPR)ong does Creally keep the Personal Data?

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data based on the following legal grounds:

(a) Contract: Processing necessary for the performance of our contract with you (providing the Services).

(b) Legitimate Interests: Processing necessary for our legitimate interests, such as improving our Services, marketing, and fraud prevention, provided these interests are not overridden by your rights.

(c) Consent: Processing based on your consent, which you may withdraw at any time.

(d) Legal Obligation: Processing necessary for compliance with legal obligations.

4. Sharing of Information

We may share your information in the following circumstances:

(a) Service Providers: With third-party vendors, consultants, and service providers who perform services on our behalf (see Sub-processors list in our Terms of Service).

(b) Business Transfers: In connection with a merger, acquisition, or sale of all or a portion of our assets.

(c) Legal Requirements: When required by law, subpoena, or other legal process, or to protect our rights, privacy, safety, or property.

(d) With Your Consent: With your consent or at your direction.We do not sell your personal information to third parties.

5. International Data Transfers

Your information may be transferred to, stored, and processed in the United States or other countries where our service providers are located. These countries may have data protection laws different from your country of residence.When we transfer personal data from the EEA, UK, or Switzerland, we ensure appropriate safeguards are in place, including:

(a) Standard Contractual Clauses approved by the European Commission;
(b) Transfers to countries deemed adequate by the European Commission;
(c) Other legally approved mechanisms.

6. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.When you delete your account, we will delete or anonymize your personal data within thirty (30) days, unless retention is required by applicable law.

7.1 Rights Under GDPR (EEA, UK, Switzerland)

If you are located in the EEA, UK, or Switzerland, you have the following rights:

(a) Access: The right to request access to your personal data.
(b) Rectification: The right to request correction of inaccurate personal data.
(c) Erasure: The right to request deletion of your personal data ("right to be forgotten").
(d) Restriction: The right to request restriction of processing of your personal data.
(e) Portability: The right to receive your personal data in a structured, commonly used format.
(f) Objection: The right to object to processing based on legitimate interests or direct marketing.
(g) Withdraw Consent: The right to withdraw consent at any time where processing is based on consent.To exercise these rights, contact us at legal@creally.co. We will respond within 30 days. You also have the right to lodge a complaint with a supervisory authority.

7.2 California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

(a) Right to Know: The right to know what personal information we collect, use, disclose, and sell.

(b) Right to Delete: The right to request deletion of your personal information.(

c) Right to Correct: The right to request correction of inaccurate personal information.

(d) Right to Opt-Out: The right to opt-out of the sale or sharing of personal information. Note: We do not sell personal information.

(e) Right to Non-Discrimination: The right not to be discriminated against for exercising your rights.

Categories of Personal Information Collected:
- Identifiers (name, email, IP address)
- Commercial information (transaction history)
- Internet or network activity (browsing history, usage data)
- Professional or employment information (company name)

To exercise your rights, submit a verifiable consumer request to legal@creally.co. We will verify your identity and respond within 45 days (extendable to 90 days if necessary).

7.3 Rights Under Other Jurisdictions

If you are located in Colorado, Connecticut, Virginia, Utah, or other states with comprehensive privacy laws, you may have similar rights to access, correct, delete, and opt-out of certain processing. Contact us at legal@creally.co to exercise these rights.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and track information about your browsing activities. Types of cookies we use:

(a) Essential Cookies: Necessary for the Site to function properly.
(b) Analytics Cookies: Help us understand how visitors interact with the Site.
(c) Preference Cookies: Remember your settings and preferences.You can control cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Services.

9. Data Security

We implement appropriate technical and organizational security measures to protect your personal data, including:

(a) Encryption of data in transit (TLS/SSL) and at rest;(

b) Access controls and authentication mechanisms;

(c) Regular security assessments and monitoring;
(d) Employee training on data protection.However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

10. Third-Party Links

The Site may contain links to third-party websites and services. We are not responsible for the privacy practices of these third parties. We encourage you to read the privacy policies of any third-party sites you visit.

11. Children's Privacy

Our Services are not directed to children under the age of 13 (or 16 in certain jurisdictions). We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child, we will take steps to delete such information promptly.

12. Do Not Track

Some browsers have a "Do Not Track" feature that signals to websites that you do not want your online activity tracked. Our Site does not currently respond to Do Not Track signals.

13. 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 Privacy Policy on this page and updating the "Last Updated" date. Your continued use of the Services after any changes constitutes your acceptance of the updated Privacy Policy.

14. Data Controller and Contact Information

The data controller responsible for your personal data is:Social Kit, Inc. (operating as Creally)2261 Market Street STE 74683San Francisco, CA 94114, USAFor privacy-related inquiries:Email: legal@creally.coGeneral support: support@creally.coIf you are in the EEA and have concerns about our data processing that we have not adequately addressed, you have the right to lodge a complaint with a supervisory authority in your Member State.

15. Information for Creators

If you are a social media influencer or content creator whose data is accessible through our Platform:

15.1 Source of Data: Your data is collected from publicly available sources, including your public social media profiles, and third-party data providers.

15.2 Purpose: Your data is processed to enable brands and marketers to discover and contact creators for potential collaborations.

15.3 Your Rights: You have the right to:

(a) Request access to the data we hold about you;
(b) Request correction of inaccurate data;
(c) Request deletion of your data from our Platform;
(d) Object to processing of your data.

To exercise these rights, contact us at legal@creally.co. We will process your request within 30 days.

15.4 Notification Exemption: Due to the volume of Creator Data processed, direct notification to each data subject is not feasible. This notice serves as notification pursuant to Article 14(5)(b) of the GDPR.