Privacy Policy

Introduction:

This Privacy Policy explains how Celetric, LLC ("Celetric," "we," "us," or "our") collects, uses, discloses, and protects personal information from users of our website, mobile application, and services (collectively, the "Service"). It applies to all users, including Merchants, Influencers (Creators), and Service Providers, as well as any visitor to our site or app. We are committed to protecting your privacy and handling your personal data in a transparent and secure way. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use our Service.

Scope:

This policy covers information that we collect through our Celetric platform and in connection with any services we offer. It does not cover any third-party websites or services that you may connect with through Celetric, except as specifically stated. Those third-party services have their own privacy practices, for which we are not responsible.

I. Information We Collect

We collect various types of information from and about our users. The types of personal information we collect may differ based on your user role (Merchant, Influencer, or Service Provider) and how you interact with the Service. Generally, the information we collect falls into a few categories: (a) information you provide to us directly, (b) information we collect automatically through your use of the Service (e.g., technical and usage data), and (c) information from third parties (such as integrated platforms or services).

A. Information You Provide Directly:

When you register for or use the Celetric platform, you may provide certain personal information, including:

a. For Merchants:

We collect information needed to set up and maintain a Merchant account and facilitate business collaborations. This may include:

1. Contact Information: Full name of the business owner or representative, business name, physical business address, phone number, and email address.
2. Business Details: Business industry, description of products or services, and other profile information you choose to provide about your company.
3. Payment Information: Preferred payment methods and financial account details necessary for transactions (for example, credit card details for paying influencer fees or bank account/PayPal for payouts if applicable). Note: Payment card information is generally collected directly by our secure payment processor (see Third-Party Services below) and not stored in our systems, apart from maybe the last four digits or tokens.
4. Identification Documents: In certain cases, we might request verification documents (such as a business license, ID, or tax ID) to confirm the legitimacy of a business.
5. Communications: Any information you provide when communicating with Influencers or Service Providers via our platform (for instance, messages, campaign briefs, contracts or agreements uploaded, etc.). These communications on the platform may be stored and monitored for compliance and support.

b. For Influencers (Creators):

We collect information for setting up an Influencer profile and enabling collaborations:

1. Contact Information: Email address is required (this will be used as your login and for notifications). We may also collect your name or username that you provide, and possibly a phone number if you choose to provide it (for two-factor authentication or communication).
2. Social Media Account Info: You may link your TikTok account or other social media accounts to Celetric. If you do so, we will collect information such as your social media username/handle, profile URL, follower count, engagement metrics, profile picture, and potentially content metrics or audience demographics (to the extent authorized by you via the social platform's API). We do not collect your social media account password; the linking is done via OAuth or similar secure methods.
3. Demographics and Interests: You might provide details such as your age or date of birth (for age verification, particularly to ensure compliance with our minimum age policy), your content categories or niches (e.g., "fashion," "tech gadgets"), language, and location (e.g., city or region) to help with matching you to Merchant campaigns.
4. Content and Portfolio: Any content you upload to your profile, such as sample videos, photos, or links to past work. This might include a bio or description you write about yourself.
5. Payment Details: If you are to receive payments (e.g., fees from Merchants), we will collect payout information such as your preferred payout method (which could be an email for PayPal, a bank account for ACH transfers, etc.) along with any necessary tax information (e.g., for U.S. influencers, we might request a W-9 form if earnings exceed certain thresholds for IRS 1099 reporting). Note for minors: If you are under 18, we will still collect your payment details, but as per our Terms, we will not process payouts to you until you are 18. (In some cases, we might allow a parent/guardian to be designated for payments if compliant with law, but that would require additional guardian information and legal arrangements).

c. For Service Providers:

We collect minimal information for a Service Provider account:

1. Contact Information: At minimum, an email address is collected for registration and communication. We may also collect your name or the name of your business, and a phone number if provided.
2. Service Details: Any information you provide about the services you offer (e.g., "photo editing services for influencers" or "marketing analytics for campaigns"). This can include a description, your website, portfolio links, or other relevant credentials you choose to share on your profile.
3. Credentials: In some cases, we may ask for proof of qualifications or references, depending on the services (for example, if you claim a certain certification, we might request evidence).
4. Payment Information: If Service Providers will receive payments through our platform, we will collect payout details (similar to Influencers) and any needed tax forms. If Service Providers pay any subscription or lead fees to Celetric (if applicable in the future), we would collect billing information as needed.

d. For All Users (General):

1. Profile Information: You may have a public-facing profile on Celetric. Any information you include in your profile (such as a profile picture, biography, company description, social media links) will be collected and may be visible to other users.
2. Communications with Us: If you contact Celetric support or communicate with us via email, chat, or phone, we will collect the information you provide (such as your name, email, the content of your inquiry, and any attachments or screenshots you send).
3. Surveys and Feedback: If you participate in any surveys, contests, or promotions we run, or provide feedback or reviews, we will collect that information.
4. Optional Information: You may choose to provide additional information not listed here to enhance your profile or experience (for example, a Merchant might upload a company logo or additional contact persons; an Influencer might provide additional social media account links; a Service Provider might add a business address). Any such information voluntarily provided is collected and treated in accordance with this Policy.

B. Information We Collect Automatically:

Whenever you use our Service (whether as a registered user or just browsing our site/app), we and our third-party analytics providers automatically collect certain technical and usage data. This includes:

a. Usage Data:

Details of how you use our platform – e.g., the pages or screens you view, features you use, the times and dates of your visits, the referring page (if you came from a link), and the links you click on our site. If you participate in a campaign or match, we may log events related to that (such as when you accept an offer, when a project milestone is marked complete, etc.). We also track communications on the platform (for example, we may log that a message was sent from user A to B at a certain time, though we handle content per our internal policies).

b. Device and Technical Data:

We collect information about the device and software you use to access the Service. This may include your IP address, browser type and version, operating system, device type (e.g., iPhone, Android, PC), device identifiers, and possibly device sensor information (like orientation, if using a mobile app). If you use our mobile app, we might collect mobile network information and the device's unique ID. This information is typically used for debugging, analytics, and personalization (for example, to remember your login on that device or to format content correctly for your screen).

c. Cookies and Similar Technologies:

We use cookies (small text files stored in your browser) and similar tracking technologies (like web beacons, pixels, and mobile identifiers) to collect information about your interactions. Cookies help us recognize you, remember your preferences, and track your actions on our site over time. For instance, we use cookies to keep you logged in during a session, to remember your language or region preferences, and to gather analytics about site traffic. We may also use cookies or pixels in emails to see if you open them or take action. You can control cookies through your browser settings and other tools (see "Your Rights and Choices" below for more on opting out of certain tracking). Note that if you disable cookies, some features of our Service may not function properly.

d. Location Data:

We may infer an approximate location for you from your IP address or based on information you provide (e.g., a city in your profile). This is typically to show you relevant content (for example, campaigns in your region) or for security (e.g., recognizing if a login comes from an unusual location). We do not collect precise GPS location from your device unless you explicitly allow it (and currently, our Service does not require or request precise location).

e. Log Files:

Our servers automatically record certain information in log files, including IP addresses, browser user-agent strings, internet service provider (ISP), referring/exit pages, date/time stamps, and clickstream data. These logs are used for troubleshooting, security monitoring, and compiling aggregated usage statistics.

C. Information from Third Parties:

Sometimes, we obtain information about you from third-party sources, which we may combine with data we already have. For example:

a. Social Media Platforms:

If you choose to register or log in through a third-party account (like signing up via Google or logging in via TikTok), that service may send us certain information such as your name, email, and public profile info, as authorized by you and that platform's terms. This helps us create your account and connect it. Also, as noted earlier, linking your TikTok or other social account can provide us with information from that account (your handle, follower count, etc.), subject to the permissions you grant. We only receive what you agree to share and what the third party's API allows. You can disconnect a linked account at any time via our settings (which stops our access to new data from that account, though we may retain what was already collected as needed).

b. Payment Processors:

When you engage in transactions, our payment processors might provide us with some information – e.g., confirmation that a payment was made, last four digits of a card for records, or notice of disputes/chargebacks. They may also provide updated information about your payment method (like an updated billing address or expiration date) if part of their service.

c. Service Providers and Partners:

We may receive information from service providers that help us with marketing or analytics. For example, an analytics provider may give us aggregated demographic data or interest segments based on your usage of our site and others. Or if we run a marketing campaign on a third-party platform, we might receive information on how you interacted with our ads outside of our site (like if you clicked an ad that brought you to our site). This data is generally used to measure the effectiveness of campaigns or to better understand our user base.

d. Other Users:

In some cases, other users might provide information about you. For instance, a Merchant might provide contact info for a representative colleague to be added to an account; an Influencer might refer a friend and give us that friend's email (we would use it only for the referral and let the friend know, per law); or if a user invites you to join a campaign via your email, we collect that email and whatever message they include. We treat such information provided by others with care and only use it for the intended purpose (e.g., to send an invite). If you believe someone has provided us your personal information improperly, please contact us and we will address it.

e. Publicly Available Data:

We might gather some information from public sources for verification or research. For example, we might view a Merchant's business website or social media to verify their legitimacy or see public reviews; or check an Influencer's public TikTok profile to verify follower count if needed. We may incorporate publicly available information into your profile (for example, adding a verified badge if we confirmed something) but we will not populate non-public personal data from such sources without your consent.

We will treat any combined information (from different sources) in accordance with this Privacy Policy.

II. How We Use Your Information

We use the collected information for various business and operational purposes consistent with providing and improving our Service, as well as communicating with you and protecting our platform. The purposes for which Celetric may use your personal information include:

A. Providing and Maintaining the Service:

First and foremost, we use your information to operate the platform and deliver the features you expect. This includes:

1. Creating and managing your account (e.g., using your email and password for login authentication, displaying your profile details to you and, where applicable, to other users).
2. Facilitating the core functions of our platform, such as allowing Merchants to post collaboration opportunities, enabling Influencers to find and apply to these opportunities, matching Merchants and Influencers based on criteria (for instance, using your profile info and preferences to recommend potential matches or show your profile in search results), and enabling Service Providers to offer their services.
3. Processing transactions and payments. We use payment and financial information to charge fees, send or receive funds on your behalf, and keep records of those transactions. For example, if you're a Merchant paying an Influencer, we use your payment method to complete that transaction and inform both parties of the payment status. If you're an Influencer getting paid, we use your payout info to send you money and may use your tax info to prepare necessary tax documents.
4. Communicating with you about your account or transactions. This includes sending confirmations, invoices, technical notices, updates, security alerts, and support messages. For instance, if you complete a campaign, we might send a summary; if someone messages you on the platform, we might send a notification; if we update our Terms or Privacy Policy, we will send you an email or notice.

B. Matching and Collaboration Features:

One of our Service's key purposes is to match Merchants with Influencers and provide collaboration tools. We use your data to:

1. Facilitate partnership matching: For example, information about Influencers (like categories of content, audience size) is used to suggest suitable influencers to merchants or vice versa. We might use algorithms that take into account profile data, past successful collaborations, location, and other factors to highlight potential matches.
2. Display relevant information to other users: If you are a Merchant, your business profile (name, industry, description, possibly location) will be visible to Influencers considering working with you. If you are an Influencer, your profile (username, bio, follower metrics, content examples) will be shown to Merchants searching for influencers. Similarly, Service Providers' offerings might be visible where relevant. We only share information that is necessary and relevant for the matchmaking purpose – for example, we would not expose an Influencer's personal email or phone to all users publicly, but once a match is made or conversation initiated, we might share contact details between the parties to facilitate direct communication (unless we provide an in-platform communication method which we prefer for safety and logging).
3. Enable communications: We use the content of messages and communications you send through our platform to deliver those messages to the intended recipients and to store them for your reference. We may also review communications if needed for trust and safety (e.g., if a dispute arises or for moderation purposes, our support team might access relevant messages).
4. Project management: If our platform includes features like setting milestones, deadlines, content submissions for review, etc., we use your data to run those. For example, if a Merchant sets a campaign deadline, we might send reminders to the Influencer; if an Influencer uploads a draft video for approval, we store and show it to the Merchant.

C. Marketing and Promotional Communications:

We may use your contact information (primarily your email, and possibly your phone number for SMS if you provided consent) to send you marketing communications. This can include:

1. Newsletters or Updates: Periodic emails about new features, tips on making the most of our platform, or company news.
2. Promotional Offers: Information about promotions, referral programs, or events we think may interest you. For example, we might send Merchants an email highlighting "Top new Influencers who joined this month," or send Influencers a note about "Brands in your category looking for collaborators." We might also promote third-party offers that are relevant to our users, but we will not share your contact info with third parties for their own direct marketing without your consent; we would typically send such offers ourselves.
3. Push Notifications: If you use our mobile app and allow notifications, we might send you push notifications for marketing or engagement purposes (like "There are new opportunities in your feed" or "Complete your profile to get more matches").

Opt-Out: You have the right to opt out of marketing emails or texts. Each marketing email will include an "unsubscribe" link. You can also adjust your notification preferences in your account settings or by contacting us. Operational and service-related communications (like account or transaction notices) will still be sent as needed.

D. Integrations with Payment and Third-Party Services:

1. For payments, as noted, we share necessary data with payment processors and use your data to initiate and track transactions.
2. If you connect other third-party services (like social media or analytics tools), we use your data as needed to enable those connections. For instance, if our platform later allows automatically posting a campaign or content on your behalf to TikTok or Instagram, we would use the tokens and permissions you gave to do so.
3. We also might use data internally to evaluate and improve such integrations (e.g., measuring how many users link TikTok accounts, and how those users engage, to decide on adding more features).

E. Service Improvements and Analytics:

1. We analyze usage data and feedback to understand which features are used most, detect usability issues, and identify areas for improvement. For example, if we see many users dropping off at a certain step of onboarding, we investigate and may adjust that process.
2. We might use aggregated data to develop new features. For instance, noticing that many Merchants search for influencers in a certain niche might prompt us to create better filtering for that niche.
3. We also use data (often in aggregated, non-identifying form) for business analysis, such as tracking growth, usage patterns, revenue, and other metrics important for running our business.
4. Information from cookies and similar is used to personalize your experience (like remembering your preferences) and to measure the effectiveness of our advertising (for example, understanding how you found our site, or whether an ad campaign is yielding sign-ups).

F. Safety, Security, and Trust & Safety:

1. Verify identities and eligibility: We may use your data (including documents you provide) to verify that you are who you claim and that you meet requirements (like age or business legitimacy). For instance, we might use third-party identity verification services to check IDs or use algorithms to detect if a social media account is likely fake.
2. Monitor for fraud and illicit activity: We actively monitor and scan for suspicious activities. This could include analyzing login locations to detect account takeovers, monitoring rapid transactions or patterns that might indicate fraud or money laundering, and using automated systems to flag content that might be prohibited (like offensive language or indications of scams in messages).
3. Enforce our Terms and policies: We will use data (including user reports and our own monitoring) to investigate and address violations of our Terms of Service or user misconduct. For example, if we receive a complaint that a user is spamming or harassing others, we will review communications and profile info as needed to take appropriate action (warning, suspension, etc.).
4. Prevent and address security incidents: If we detect an attempted breach or an actual data security incident, we will use relevant data (like logs) to identify the source and scope, and to mitigate it. We may also use your contact info to inform you of security issues (e.g., sending an alert if we suspect unauthorized access to your account).
5. Legal compliance: We may process your personal information as required by law or legal process, such as to respond to a subpoena or lawful request by law enforcement (more in "Legal Obligations" below).

G. Legal Obligations and Rights Protection:

1. Compliance: To comply with various laws – for instance, keeping certain transaction records for accounting/tax purposes, or data required by financial regulations (like KYC – "Know Your Customer" information if applicable for payments).
2. Dispute Resolution: If there's a dispute or legal claim, we will use relevant data to defend our rights or resolve the issue. For example, if you raise a claim or if we are involved in litigation, relevant communications and records will be used as evidence as needed.
3. Enforcing agreements: We may use data to enforce agreements we have with you or others, and to collect fees or damages owed to us.
4. Protecting rights and preventing harm: We may use and share information as necessary to protect the rights, property, or safety of our users, Celetric, or the public. This includes exchanging information with other companies and organizations for fraud protection or investigating potential wrongdoing on the platform.

H. Other Purposes (with Notice to You):

If we intend to use your personal data for any purpose that is not compatible with the purposes listed above, we will describe how we intend to use it at the point we collect it or obtain your consent. For example, if in the future we envisioned a new use of data not covered by this policy, we would update this policy and/or seek your consent as required. We will not use your personal information in ways that have materially different privacy impacts without adequate notice and consent.

We ensure that we have a valid legal basis for processing your information. In most cases for users in the United States, our processing is justified by the need to perform our contract with you (the Terms of Service), our legitimate business interests (such as improving the service, securing it, and marketing our services), compliance with legal obligations, or your consent (for things like certain marketing or accessing third-party accounts).

III. How We Share Your Information

Celetric understands the importance of your personal information and will only share it in certain circumstances. We do not sell your personal data to third parties for their independent marketing purposes. We share information with third parties in the following cases:

A. Sharing Among Users:

1. Public Profiles: When you create a profile on Celetric, certain information is public or semi-public on the platform. For Merchants, this might include your business name, description, industry, and possibly profile image and location (city, state). For Influencers, it could include your display name or handle, bio, content categories, follower statistics, and linked social profiles. For Service Providers, it could include your service name, description, and any portfolio or website you added. Direct contact information like email, phone, or full address is not publicly displayed to all users on a profile, but may become visible to another party when you enter a collaboration or if you provide it in a message.
2. Matching and Searching: As mentioned, our platform's search and discovery features will display user profiles to other users. For example, a Merchant can search for Influencers by category and see their profiles; an Influencer might browse Merchant campaign listings which include Merchant profiles. This sharing is intrinsic to how the Service works – making connections.
3. Collaboration Details: When a Merchant and Influencer agree to work together (or a Merchant engages a Service Provider), we will facilitate the exchange of necessary information. Once matched or in negotiation, a Merchant might see an Influencer's contact details (and vice versa) to coordinate off-platform if needed (though we encourage using on-platform messaging for records). Also, any deliverables (like content files, briefs, contracts) shared in the context of the project are visible to the parties involved. If a Merchant sets up a campaign that multiple influencers apply to, the Merchant will see info on those applicants, etc.
4. Reviews/Feedback: If our platform allows users to review or rate each other after a collaboration, those reviews (along with your name and perhaps profile link) will be visible to other users. For example, an Influencer's profile might show that they have a 5-star rating from X number of Merchants, and specific testimonials may be visible. Likewise for Merchants receiving ratings from Influencers. We will moderate such feedback for appropriateness but it is a form of user-generated content that is shared to maintain trust and transparency in the community.

We urge you to be mindful of what information you share in your profile or communications on the platform, especially if you put personal contact info in areas that might be visible to others. Use built-in private fields for contact info when possible.

B. Service Providers (Third-Party Vendors):

We employ third-party companies and individuals to help us operate and improve the Celetric Service. These third-party service providers perform tasks on our behalf and under our instructions (as "processors" of data) and include categories such as:

1. Payment Processors: As described, companies like Stripe, PayPal, or banking partners process financial transactions. They receive the necessary personal data to process payments, such as your name, billing address, credit card details or bank account, and transaction amount. They may also store payment information for future transactions if you choose (e.g., card token for one-click payments). These providers are responsible for safeguarding that information and are generally PCI-DSS compliant for credit card data.
2. Cloud Hosting and IT Infrastructure: Our website and databases may be hosted on third-party infrastructure (e.g., Amazon Web Services, Google Cloud). These providers may process all categories of data stored on our systems but only for the purpose of storage and retrieval; they do not access data for any independent purpose. Data at rest and in transit may be encrypted for additional protection.
3. Email and Communication Tools: We use email delivery services (like SendGrid, Mailchimp, or similar) to send out verification emails, notifications, and newsletters. These services get access to your email address and the content of emails we send to you. If we send SMS messages, we would use an SMS gateway (like Twilio) which gets your phone number and message content.
4. Analytics and Performance Monitoring: Services such as Google Analytics or other analytics tools help us understand usage. They may set cookies and collect usage data and device identifiers (usually anonymized or aggregated). We might also use error tracking services or crash reporting in our app (which could include user device info and possibly user identifiers in crash logs to debug issues).
5. Marketing and Advertising Partners: We might share limited data with marketing partners to measure and improve our marketing efforts. For example, we could upload a list of user emails in hashed form to an ad platform like Facebook or Google to create a "custom audience" for ads (to avoid showing you ads if you're already a user, or to find similar people). This data is typically used in a privacy-safe way and the third party cannot identify individuals from the hash. Another example: if we run a joint webinar with a partner, and you sign up, we might share your registration info with the co-host per your expectations.
6. Background Check / Verification Services: If we decide to conduct more thorough verifications (like identity or background checks for fraud prevention or for certain high-value collaborations), we might use specialist services. They would receive identifying information (like name, address, possibly SSN or ID number) and return a verification result or additional data (like a verified status). We would only do this in accordance with applicable law and with your knowledge (for example, asking you to submit to a KYC check).
7. Customer Support Software: If you interact with our support (via chat widget or email), the platform we use (Zendesk, Intercom, etc.) will process your contact info and the conversation. They store these communications for our reference and quality assurance.
8. Other Tools: We may use various other tools to help with things like scheduling emails, managing feature flags, content filtering (some platforms use third-party AI to detect inappropriate content), etc. These tools might incidentally process some user data in performing their functions.

We only share with service providers the information that is reasonably necessary for them to perform their work. They are contractually obligated to protect your data, use it only for our instructed purposes, and maintain confidentiality. They also must comply with applicable data protection laws. We do not allow our vendors to use the personal information we share for their own direct marketing or any purposes other than those related to providing services to us.

C. Integration Partners and Third-Party Platforms:

If you specifically integrate or use third-party platforms through our Service, we will share information with them based on your instructions. Examples include:

1. If an Influencer connects a TikTok account, we send information to and from TikTok's API to link the account (such as an authentication token, your TikTok user ID, etc.). This allows us to fetch your TikTok profile data and maybe post content (if that feature exists).
2. If we implement a feature like "Log in with Google/Apple," those identity providers receive a request from us and confirm your identity to us (and they may receive info that you logged into Celetric using their service).
3. If a Merchant uses a third-party tool via our platform (for example, importing campaign data from an e-commerce platform or exporting reports to a marketing system), we will share data with that tool as needed. This only happens with your consent when you initiate such actions.
4. Any third-party plugins or widgets on our site (like a social media "share" button) may collect certain data like your IP and which page you're on, under their own privacy policies. We will endeavor to minimize such sharing and will inform you where such cases occur.

D. With Affiliates and Corporate Transactions:

Celetric is currently an independent company (Celetric, LLC). If we have affiliate companies (under common ownership or control now or in the future), we may share your information with them if needed to help provide the Service or for internal business operations (for example, if we open a branch or subsidiary in another region that handles local marketing or customer support). Any affiliate will be required to honor this Privacy Policy.

In the event of a business transfer – such as a merger, acquisition by another company, sale of all or part of our assets, or in connection with a financing, or transition of service to another provider – your personal information may be among the assets transferred. We would ensure that any successor entity either continues to abide by this Privacy Policy or notifies you of any changes. You would have the opportunity to stop using the Service or delete your data if you object to the new policies after such a transfer.

E. For Legal Compliance and Protection:

1. Comply with the law or legal process: This includes responding to subpoenas, court orders, or other legal requests (like law enforcement inquiries). We will evaluate each request to ensure it has a valid legal basis and is not overly broad. Where allowed, we might notify you of such requests.
2. Protect rights and enforce agreements: We may need to disclose data to enforce our Terms of Service or other agreements, or to collect owed amounts, or to address fraud or security issues. For example, if a user is engaged in fraud that affects third parties, we might share data with those third-party victims or relevant authorities.
3. Address emergencies: If someone's safety is at risk, we may share information to prevent harm. For instance, if we have data indicating an imminent threat to the life or security of any person, we could provide information to authorities to mitigate that threat.
4. Resolve disputes and legal claims: If you have a dispute with another user, we might (with your consent or as necessary) share relevant information with that user or an arbitrator/legal authority to help resolve the issue. If our company is involved in a legal claim, we might need to provide data as evidence.

Any such sharing will be done in accordance with applicable laws. We also reserve the right to report to law enforcement any activities that we believe to be unlawful or for which we believe we are legally required to report.

F. With Your Consent:

Apart from the situations above, we will share your personal information with third parties only if you give us consent to do so. For example, if you ask us to share your information with a partner company or if you opt-in to a feature that involves sending your info to a third party, we will do so per your instructions. You might grant consent in various ways: clicking "allow" in a prompt, adjusting your account settings to enable a sharing feature, or in writing. You can revoke your consent at any time for future sharing by contacting us or turning off the setting (though any sharing already done with your consent cannot be undone).

Important: Celetric's default approach is to minimize data sharing. We use and share data in order to run and improve the service, facilitate user connections, and comply with law. We want to emphasize that we do not sell personal information to data brokers or advertisers. If in the future our practices change in a way that involves more expansive sharing, we will update this Privacy Policy and provide choices as required by law (for instance, offering an opt-out if required).

IV. Your Rights and Choices

We believe in user rights when it comes to personal data. Depending on your location and applicable law, you may have certain rights regarding your personal information. We also provide various ways for you to control the data we have about you and how we use it. Below is a summary of these rights and choices:

A. Access and Portability:

You have the right to request access to the personal data we hold about you. This includes the right to ask for a copy of the information in a commonly used format. For example, you can request a copy of your profile data, settings, communications, and transaction history. We will provide this data, usually electronically. (If you have an account, many of these details are available in your profile or dashboard already.) In certain jurisdictions (like under GDPR in Europe or CCPA in California), this is known as a "Data Subject Access Request." We will comply with such requests as required by law.

B. Correction (Rectification):

If you believe that any personal information we have about you is incorrect or incomplete, you have the right to request that we correct or update it. You can also make most edits yourself by logging into your account (e.g., updating your profile info, changing your contact details). If you are unable to change something or want us to ensure it's corrected throughout our systems, contact us with the details and the correct information, and we will address it promptly, as long as we can verify the accuracy of the new information.

C. Deletion (Right to be Forgotten):

You can request that we delete your personal data. This can be done by:

a.For the【Celetric】APP, you can delete your account by following the path:【My】—【Settings】—【Account and Security】—【Account Deletion】

b.For the 【Celetric-Business】APP, you can delete your account by following the path: 【My】—【Personal Center】—【Delete Account】

c.For the【Celetric-Creator】APP, you can delete your account by following the path: 【My】—【Settings】—【Account and Security】—【Delete Account】

This typically initiates a process to remove personal information from our active databases.

D. Opt-Out of Marketing:

As mentioned, you may opt out of receiving promotional communications from us. You can do this by:

1. Clicking the "unsubscribe" link in any marketing email you receive.
2. Replying "STOP" to a marketing SMS (if one was sent in compliance with consent requirements).
3. Adjusting notification settings in the app or site (if available) to turn off marketing notifications.
4. Contacting our support to request removal from marketing lists.

Note that even if you opt out of marketing, we may still send you transactional or service-related communications (like account alerts, password reset emails, notifications of important changes to the service or policy, etc.), as these are not promotional.

E. To verify your identity and secure your account, we will send SMS messages containing one-time verification codes to your provided phone number. Standard carrier message rates may apply. You may opt out by not completing verification or replying STOP to any message.

F. Cookies and Tracking Choices:

1. Browser Cookies: Most web browsers allow you to manage cookies through their settings (you can usually block or delete cookies). However, disabling cookies might affect how certain parts of our Service function (for example, you may need to log in every time or some features might not remember your preferences). Our Cookie usage is primarily for essential functions, but also for analytics. If you want to opt out of analytic cookies, you can often do so by using tools provided by services like Google Analytics (e.g., the Google Analytics Opt-out Browser Add-on).
2. Do Not Track: Some browsers have a "Do Not Track" (DNT) feature that signals to websites that you do not want to be tracked. Our Service at this time does not respond to DNT signals due to lack of a common standard, but we treat all users' data as described here, and we give you direct ways to control data regardless of DNT.
3. Advertising Opt-Out: If we engage in any advertising that uses your data, we will provide appropriate opt-outs. For example, if we ever do interest-based advertising using third-party cookies or devices identifiers, we will inform you and you can opt out via industry programs (like the Network Advertising Initiative or DAA's WebChoices for web, or platform settings on iOS/Android for mobile ads). As of the latest update, our focus is not on advertising other than promoting our own service.

F. California Privacy Rights:

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) (and as updated by the CPRA effective 2023) if applicable to our service. These include the right to know the categories of personal information we collect about you, the categories of sources of that information, the business purpose for collection, the categories of third parties with whom we share it, and specific pieces of information we hold. We've provided much of this information in this Privacy Policy. You also have rights to request deletion of your personal information, to opt-out of "sale" or "sharing" of personal info (we do not sell data as defined, but if certain cookie or advertising practices qualify as "sharing" for cross-context behavioral advertising, you can opt-out via cookie settings or contacting us), and the right not to be discriminated against for exercising your privacy rights. If CCPA applies, you or your authorized agent can submit requests via the contact methods below. We will verify requests by asking you to log into your account or provide information that matches our records.

G. European/UK Data Subject Rights:

If you are in the European Economic Area (EEA), United Kingdom, or a jurisdiction with similar laws (e.g., GDPR), you have the aforementioned rights (access, rectification, deletion) and additional ones: the right to restrict processing (ask us to limit how we use your data, e.g., while a complaint is being resolved), the right to object to processing (particularly for direct marketing or when processing is based on legitimate interests), and the right to data portability (to get your data in a structured, commonly used format, or have it transmitted to another controller where technically feasible). You also have the right to lodge a complaint with your local data protection authority if you believe we have not complied with your rights or data protection laws. While our primary operations are in the US and we currently target NY/NJ, we are committed to upholding these principles should they be relevant. At this time, our Service is primarily U.S.-focused, but we anticipate complying with GDPR standards if and when applicable.

H. Managing Social Connections:

If you have linked your Celetric account with third-party accounts (e.g., TikTok, Google), you can manage those connections in your account settings. You typically have the ability to disconnect an account, which stops further data access. However, note that it doesn't retroactively delete data we already obtained from that account. If you want that data deleted, you should make a deletion request as described above. Also, to fully revoke our access to a social account, you may need to adjust settings in that third-party account (for example, remove Celetric's app permissions from your TikTok/Google account settings).

I. Retention:

We retain your personal information for as long as your account is active or as needed to provide you services. If you deactivate or delete your account, we will endeavor to delete or anonymize personal data, but as noted, certain data may be retained for legal or internal purposes. We store data as long as necessary for the purposes described (which may extend beyond your active use, for example, if we have to keep some records for tax or dispute purposes). We also periodically review the data we have and delete or anonymize information that is no longer needed. For instance, if you started signing up but never completed registration, we might remove your partial data after some time. Or if you have not logged in for a very long period, we might purge certain information.

We will respond to legitimate requests relating to your rights as promptly as possible, and certainly within any timeframes set by law (e.g., within 30-45 days for CCPA/GDPR requests, potentially extendable by another period if necessary with notice to you). To exercise any rights, you typically can contact us at the contact information provided in this Policy (see section "Contact Us" below). For certain things like opting out of emails, it might be quickest to use the provided unsubscribe mechanism.

Please note that for security, we might require verifying your identity before fulfilling certain requests (especially for access, deletion, or portability). This could involve asking you to confirm some personal details we have on file, or verifying control of your email. If an authorized agent is making a request on your behalf, we will take steps to verify the agent's authority and potentially also confirm with you.

We are committed to respecting your rights and will not retaliate or deny you service for exercising your privacy rights (though certain choices, like deletion, might mean we can't provide certain features to you if the data is necessary for them).

V. Data Security

Celetric takes the security of your personal information seriously. We implement a combination of administrative, technical, and physical security measures designed to protect your data from unauthorized access, disclosure, or destruction. However, please be aware that no method of transmitting or storing data is completely secure, and while we strive to protect your personal information, we cannot guarantee absolute security.

Some of the measures we have in place include:

1. Encryption: We use encryption to protect data in transit and at rest. Our website is served over HTTPS, which means personal data exchanged between your browser/app and our servers is encrypted using TLS (Transport Layer Security). Sensitive information (like passwords) is also encrypted or hashed in our database. For instance, we store passwords using strong cryptographic hash functions (and never in plain text). Payment information is handled by third-party processors that comply with PCI standards; if any payment data is stored by us (like routing numbers for direct deposits), we use encryption and secure tokenization as provided by payment processors.
2. Access Controls: Internally, we restrict access to personal information to employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Service. Those who have access are bound by confidentiality obligations. We use role-based access controls, meaning staff only have access to the data necessary for their role. For example, our support team may see your profile and message history to help with an issue, but they would not have access to your full payment information. Our developers may have broad database access but handle data only for debugging or improving the service under strict oversight.
3. Secure Development Practices: We follow secure coding guidelines and periodically review our application for vulnerabilities. We keep our software frameworks and libraries up to date to patch security issues. We also may employ third-party security tools or experts to test our systems (penetration testing, code audits, etc.).
4. Network and System Security: Our servers are protected by firewalls, and we utilize intrusion detection/prevention systems. We monitor our systems for possible vulnerabilities and attacks. Data centers hosting our servers have their own robust physical security (guards, access badges, cameras, etc.). Backups of data are performed to ensure availability, and those backups are stored securely (with encryption).
5. Account Security Features: We encourage you to help keep your account secure by choosing a strong password and keeping it confidential. We provide the option (and recommend) using two-factor authentication (2FA) if available. With 2FA, even if someone guesses or obtains your password, they would still need a secondary code from your device to log in. We also monitor account login attempts and may implement additional verification or limits if suspicious activity is detected (for example, if a login occurs from a new device or location, we might send you an alert or require additional confirmation).
6. Payment Security: As noted, we partner with reputable payment processors for handling financial data. We do not see or store full credit card numbers; such sensitive data goes directly from you to the payment provider through secure channels. Our platform might store tokens or references needed to process charges, but not the raw card details. Any payment information we do store (like payout bank accounts) is kept in encrypted form.
7. Employee Training: We train our team members about the importance of data privacy and security. They are trained to spot phishing attempts, handle user data carefully, and follow internal security protocols. We also require our employees to use security best practices in their work (such as using password managers, enabling 2FA on accounts, etc.).
8. Incident Response: We have an incident response plan in case of a security breach or suspected incident. If a data breach were to occur that affects your personal information, we will notify you and relevant authorities as required by law, and we will take steps to mitigate any harm.

Despite all our efforts, it's important for you, the user, to also play a part. Protect your account credentials: Don't reuse passwords from other sites that may be less secure, enable 2FA if possible, and be cautious of phishing attempts (Celetric will never ask you for your password via email, for example). Also, remember to log out when using shared devices and use secure networks when accessing sensitive info.

If you have reason to believe that your interaction with our Service is no longer secure (for instance, if you feel your account has been compromised), please contact us immediately so we can assist.

VI. Children's Privacy

Protecting the privacy of young users is especially important. Celetric is not directed to children under the age of 13, and we do not knowingly collect personal information from anyone under 13 years old without verifiable parental consent. If you are under 13, you are not permitted to use our Service or provide any personal information to us.

As outlined in our Terms of Service, minors aged 13 to 17 are allowed to have an account only with parental/guardian permission and supervision, and with the understanding that they cannot access certain features (like withdrawing earnings) until they reach 18. We expect users between 13 and 17 to use the Service in compliance with applicable laws, including any requirements for parental consent in their jurisdiction.

For Parents and Guardians: If you are a parent or legal guardian who has allowed your minor (under 18) to register on Celetric, it is your responsibility to supervise their use of the Service. We strongly encourage you to discuss online safety and privacy practices with your teen. You should know that the minor's profile information (as provided by them) may be visible to other users as described above, and they may interact with adults on the platform in a professional context (like collaborating with a Merchant). We try to create a safe environment with conduct rules and monitoring, but we also rely on parental oversight for minors.

If you become aware that a child under 13 has provided us with personal information, please contact us immediately. If we learn that we have collected personal information from a child under 13 without parental consent, or if a child under 13 has been improperly using our Service, we will take steps to terminate the child's account and delete such information from our records as quickly as possible. For minors aged 13-17, if we find they are using the Service without the required guardian consent or in violation of our minor policies, we may suspend or restrict the account until proper consent is obtained or until they are 18.

We also comply with the Children's Online Privacy Protection Act (COPPA) in the US and similar laws that may apply in other jurisdictions regarding children's privacy. That means any content aimed at children or any collection of data from children under 13 (if ever applicable in some context of our Service) would be handled in accordance with those strict requirements, including obtaining parental consent and providing access to and control over the child's data to the parent.

If you have any questions about children's privacy on our platform or if you want to report an account that you believe belongs to an under-13 child or an unsupervised minor, please reach out to us via the contact information in this Privacy Policy.

VII. International Users and Data Transfers

Celetric is based in the United States (with company registration in Delaware) and our Service is primarily targeted to users in the United States (initially focusing on New York and New Jersey). If you are accessing the Service from outside the United States, please be aware that your personal information will likely be transferred to, stored, and processed in the United States (and possibly other countries where our infrastructure or service providers are located). The data protection laws of the United States or those other countries may not be as comprehensive or equivalent to the laws in your country of residence.

However, we take steps to ensure that your privacy is protected as outlined in this Privacy Policy, regardless of where your data is processed. For example, if you are from the European Economic Area (EEA) or UK, we would implement appropriate safeguards (such as standard contractual clauses or relying on service providers that certify to frameworks like EU-U.S. Data Privacy Framework, if applicable) for any international data transfers, since the EU considers the US not to have an "adequate" level of data protection by itself.

By using our Service, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this policy.

If international expansion occurs and we have users from other countries, we will update our practices as needed to comply with country-specific requirements. For instance, if offering services in the EU, we'd comply with GDPR fully (legal bases for processing, possibly appointing an EU representative, etc.), or if in other countries like Canada, Brazil, etc., we would adhere to those privacy laws. As of now (2025), since our primary user base is US-based, we focus on US law compliance (with voluntary alignment to some international best practices).

For users in jurisdictions with data localization laws (that require certain data to stay within a country), please note that using a global platform like ours means your data will be transferred cross-border. If you do not want your data to leave your country, you should not use the Service. If at some point we set up local servers or entities to handle data in specific regions (for instance, storing data of EU users in EU data centers), we will inform the affected users and reflect that in the policy.

VIII. Updates to this Privacy Policy

We may update or modify this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will post any revised Privacy Policy on our website/app with a new "Last Updated" date at the top. If the changes are significant, we will provide a more prominent notice (such as by email notification to registered users or by placing a notice on our site's homepage or within the app).

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the Service after any update to this Privacy Policy constitutes your acceptance of the changes. If you do not agree to the updated policy, you should stop using our Service and may request us to delete your data as outlined above.

For any material changes that require consent (for example, if in the future we plan to use your data for a new purpose that you didn't agree to before), we will seek your consent. We might do this by providing an opt-in within the Service or via communication asking for your agreement.

Historical versions of this Privacy Policy can be provided upon request so you can see how it has evolved.

IX. Contact Us

If you have any questions, concerns, or requests regarding this Terms of Service or Privacy Policy, or about how your information is handled, please do not hesitate to contact us. We are here to help and address any issues.

Contact Information:

Email: Info@celetric.com

Address: Celetric, LLC – Privacy Department
1234 Example Street,
Wilmington, DE 19801, USA
(Note: Use the actual business mailing address. Delaware registration might use an agent address, but you might provide a contact address for correspondence.)

Contact Form: You may also reach us through a contact form on our website (if available) by selecting "Privacy Inquiry" or similar.

Customer Support: If you are a registered user, you can also contact us via the in-app support chat or help center.

We will respond to inquiries as soon as reasonably possible, generally within a few business days. If you are contacting to exercise any of your privacy rights, please include enough information for us to verify your identity (such as the email associated with your account and a specific request detail).

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, and we are subject to an independent dispute resolution mechanism (for example, if we were part of Privacy Shield or similar, we would list that), you may contact that mechanism. (Currently, since we are not in such a framework, you'd typically escalate by contacting regulators if needed, but we aim to resolve directly.)

Thank you for reading our Privacy Policy. We value your trust and are dedicated to protecting your personal information and privacy while providing you with a valuable platform for collaboration.