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Privacy & GDPR Policy

Last Updated: June 10, 2026

Table of Contents

1. Data Controller Information

For the purposes of the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018, the data controller responsible for your personal data is:

ALTEREGO AGENT LTD
Company Registration Number: 16995431
Registered Address: 128 City Road, London, EC1V 2NX, United Kingdom
VAT Registration Number: GB518359863

We are committed to protecting the privacy, confidentiality, and security of all personal data we process in relation to our users, partners, and visitors.

2. What Personal Data We Collect

We collect personal data that you provide directly to us, data generated by your use of our Platform, and data imported from third-party social networks. This includes:

  • Identity & Contact Data: First name, last name, business name, username, email address, password, billing address, and corporate VAT registration details.
  • Creator Profile Data: Social media handles (Instagram, TikTok, YouTube, etc.), category/niche preferences, content examples, biography, and location.
  • Campaign & Deal Data: Application details, briefs, contract terms, text, photo, and video deliverables, live campaign links, and chat messages between Brands and Creators.
  • Financial & Transaction Data: Stripe account details, invoice records, payment card tokens, earnings, payouts, and transaction history. *(Note: We do not store full credit card numbers; these are handled directly by our PCI-compliant payment processor, Stripe).*
  • Consent Logging Data: For legal audit trails, we log the user ID, accepted terms version, accepted privacy version, accepted cookie version, IP address, user agent, and timestamp at the moment of registration.
  • Technical & Usage Data: IP address, browser type and version, time zone setting, operating system, and information on how you interact with the Platform (pages viewed, click patterns).

3. Purposes & Legal Bases for Processing

Under UK GDPR, we must have a lawful basis to process your personal data. We rely on the following bases:

Processing Purpose Lawful Basis Under UK GDPR
Creating and managing user accounts (Brands & Creators) Performance of a Contract (Article 6(1)(b))
Facilitating campaign applications, approvals, and deal agreements Performance of a Contract (Article 6(1)(b))
Processing payments, invoices, and payouts (via Stripe) Performance of a Contract & Legal Obligation (Article 6(1)(b) & (c))
Answering support tickets and resolving platform disputes Performance of a Contract & Legitimate Interests (Article 6(1)(b) & (f))
Improving platform security, performance, and user experience Legitimate Interests (Article 6(1)(f))
Logging legal terms and policy consent metrics Legal Obligation & Legitimate Interests (Article 6(1)(c) & (f))
Complying with statutory accounting and tax reporting obligations Legal Obligation (Article 6(1)(c))

4. Marketing & Email Communications

We handle marketing emails and system notices strictly in accordance with UK PECR rules and the UK GDPR:

  • Transactional & Service Updates: Emails related directly to your account activity, payments, support tickets, and changes to our terms are strictly transactional and necessary to perform our contract with you (Article 6(1)(b) UK GDPR). You cannot opt out of these.
  • Consumer/Creator Marketing (B2C): Newsletters and promotional emails sent to individual creators or influencers are sent only where you have given your explicit opt-in Consent (Article 6(1)(a) UK GDPR).
  • Corporate/Brand Marketing (B2B): Marketing communications sent to corporate brand representatives are based on our Legitimate Interests in promoting our platform to businesses (Article 6(1)(f) UK GDPR). We carry out a Legitimate Interests Assessment (LIA) to balance our interest with your privacy rights.
  • Unsubscribe: Every promotional or marketing email we send contains a clear, one-click "Unsubscribe" link in the footer to allow you to opt out immediately.

5. Sharing Your Personal Data

We do not sell your personal data. We only share personal data as necessary to provide our services, comply with legal requirements, or protect our rights:

  • Between Brands and Creators: To enable campaigns and deals, we share Creator profiles (handles, niche, stats) with registered Brands. Once a deal is formed, contact details and communications are visible to both parties.
  • Service Providers: We share data with trusted third-party sub-processors who help us run the Platform:
    • Stripe, Inc.: For secure payment, identity verification, and payout processing.
    • Hosting Providers: Secure servers and cloud storage in the UK/EEA.
    • Email & Support Services: To send transactional emails and manage customer support.
  • Legal & Regulatory Authorities: We may disclose your data to law enforcement, tax authorities (such as HM Revenue & Customs - HMRC), or regulatory bodies when required to do so by the laws of England and Wales.

6. International Data Transfers

Your personal data is primary stored and processed on secure servers located within the United Kingdom and the European Economic Area (EEA).

If we transfer your personal data outside the UK or EEA to a country that does not have an adequacy decision by the UK Government or European Commission, we ensure appropriate safeguards are implemented. This typically includes entering into the UK International Data Transfer Agreement (IDTA) or the European Commission's Standard Contractual Clauses (SCCs) alongside the UK Addendum.

7. Data Retention

We retain your personal data only for as long as is necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or tax reporting requirements.

By law, we must keep basic transaction and tax-related information (including invoices, payments, and contract approvals) for 6 years after the tax year in which the transaction took place, to comply with UK tax regulations and corporation laws.

Non-transactional account data is typically deleted or anonymized within 12 months after account closure, unless there is an active dispute or legal hold.

8. Your Data Protection Rights

Under the UK GDPR, you have the following rights in relation to your personal data:

  • Right of Access (Subject Access Request): You have the right to request copies of your personal data from us.
  • Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
  • Right to Erasure ("Right to be Forgotten"): You have the right to request that we erase your personal data under certain conditions, subject to our statutory retention periods (e.g. tax laws).
  • Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data under certain conditions.
  • Right to Object to Processing: You have the right to object to our processing of your personal data, particularly where we rely on legitimate interests or direct marketing.
  • Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, in a structured, commonly used, and machine-readable format.
  • Right to Withdraw Consent: Where we rely on your consent to process your data, you can withdraw consent at any time.

To exercise any of these rights, please contact us by email at info@alteregoagent.com or at our registered corporate address. We will respond to your request within one calendar month.

9. Security of Your Data

We use rigorous technical and organizational security measures to protect your personal data from accidental loss, unauthorized access, alteration, or disclosure. All traffic to the Platform is encrypted using Secure Socket Layer (SSL/TLS) technology. Payment operations are fully delegated to PCI-DSS compliant payment gateways.

However, please be aware that no transmission of data over the internet can be guaranteed to be 100% secure. You are responsible for maintaining the confidentiality of your account password.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal obligations. We will notify you of any significant changes by posting the new policy on this page and updating the "Last Updated" date at the top.

11. Contacting the ICO & Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us by email at info@alteregoagent.com or at:

ALTEREGO AGENT LTD
Data Protection Contact
128 City Road, London, EC1V 2NX, United Kingdom
Email: info@alteregoagent.com

If you are not satisfied with our response or believe we are processing your personal data unlawfully, you have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner's Office (ICO). You can find contact details on their website: https://ico.org.uk.