INFLUENCE360 PRIVACY POLICY

This Privacy Policy replaces the prior Influence360 Privacy Policy from the Effective Date above. It should be read together with the Influence360 Terms of Service, including any Campaign-specific or Points and Referral Program terms incorporated into those Terms.

1. Introduction

Influence360 - F.Z.C ("Influence360", "we", "us" or "our") is a Free Zone Company - Limited Liability incorporated in Ajman Free Zone, United Arab Emirates, under Licence / Registration No. 41123, with registered office at Office - C1 - 1F - SF5820, Ajman Free Zone C1 Building, Ajman, United Arab Emirates.

This Privacy Policy explains how we collect, use, disclose, store, transfer and protect personal data when you access or use the Influence360 digital platform, including websites, applications, dashboards, APIs, analytics, campaign-management tools, creator and referral features, Points and gamification programs, messaging tools, the Publication Module and related services (collectively, the "Platform").

Influence360 currently operates under the following Ajman Free Zone activities: Marketing Management; Project Management Services; Social Media Applications Development & Management; and Data Classification and Analysis Services. References in this Policy to Campaign management, creator and referral functionality, analytics, scoring, the Publication Module and related Platform functions describe processing carried out in connection with those licensed activities and any other approvals lawfully held by Influence360 from time to time.

This Policy is intended to address applicable privacy and data protection requirements, including, where applicable, UAE Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data (UAE PDPL), the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA) as amended, other applicable U.S. state privacy laws, Brazil LGPD, Canada PIPEDA and similar laws.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy. Where consent is required by applicable law for a particular processing activity, we will request it separately.

2. Data Controller, Processor and Business Status

2.1 Influence360 as controller

Influence360 - F.Z.C is generally the data controller for personal data used to operate the Platform, manage User accounts, provide marketing-management and project-management services, administer Creator and Publication Campaigns, operate Points, referral and gamification programs, provide analytics and scoring, secure the Platform, issue invoices, manage support and comply with legal obligations.

2.2 Influence360 as processor

In limited circumstances, a Company may provide personal data to Influence360 and instruct Influence360 to process that data solely on the Company's behalf for a specific Campaign or service. Where required, the parties may enter into a separate data processing agreement. The applicable role depends on the facts and the relevant processing activity.

2.3 Publications and other Users

Publications, Companies, Content Creators and other independent Users may act as separate data controllers for personal data they receive or collect for their own purposes. For example, when a Client purchases a Publication Service, the relevant Publication may receive business contact details, Client Materials and Campaign information needed to review and deliver the requested publication or media service. Companies may also receive Creator or conversion-related information needed to administer a Creator Campaign. Each independent controller is responsible for its own privacy obligations.

2.4 U.S. privacy status

For purposes of applicable U.S. state privacy laws, Influence360 acts as a business or controller where those concepts apply. Influence360 does not knowingly sell personal information and does not share personal information for cross-context behavioral advertising as those terms are defined under the CCPA, unless we provide a specific notice before changing that practice.

3. Scope and Applicability

This Privacy Policy applies to personal data relating to:

  • registered Users and account administrators;
  • Companies and their employees, contractors and authorized representatives;
  • Content Creators, influencers and participants in Awareness, Conversion and Open Creator Campaigns;
  • participants in Points, referral, leaderboard, creator-status and other gamification or rewards programs;
  • Publications and their account administrators, sales, advertising, editorial or operations contacts;
  • Clients using the Publication Module, including self-service and Account Manager-assisted Campaigns;
  • visitors and browsers of the Platform;
  • persons who contact support, sales, legal or compliance teams; and
  • other individuals whose personal data is lawfully processed in connection with Campaigns, referrals, attribution, analytics or Platform operations.

Where local law gives you additional rights, those rights apply to the extent required by that law.

4. Lawful Bases for Processing

Depending on the jurisdiction and the processing activity, we rely on one or more of the following legal bases:

  • performance of a contract or steps requested before entering a contract, including account creation, Campaign administration, Creator Campaign participation, Points or referral program participation, Publication Campaign orders, invoicing and service delivery;
  • compliance with legal obligations, including tax, accounting, sanctions, regulatory, fraud-prevention and lawful disclosure requirements;
  • legitimate interests, including Platform security, fraud prevention, attribution, service improvement, Campaign analytics, scoring and ranking, data classification, creator matching, business continuity, dispute handling and protecting legal rights, where those interests are not overridden by applicable privacy rights;
  • consent, where consent is required, including certain marketing communications, optional account connections, non-essential cookies, pixels or tracking technologies; and
  • other lawful grounds available under applicable law.

Where we rely on consent, you may withdraw it at any time without affecting processing that occurred before withdrawal. Certain processing is necessary to provide the Platform, verify Campaign activity or administer a requested program and cannot be stopped without affecting or ending that service or participation.

5. Categories of Personal Data We Collect

5.1 Identifiers, account and business-contact data

  • name, username, job title and professional role;
  • email address, telephone number and other contact details;
  • company, project or Publication name and business affiliation;
  • account role, such as Company, Content Creator, Publication administrator or other User;
  • account credentials and authentication information, stored in protected form;
  • linked social media accounts and public account identifiers;
  • third-party platform identifiers associated with connected accounts; and
  • preferences, settings and account status.

5.2 Publication Module and Campaign data

When you use the Publication Module or participate in a Publication Campaign, we may process:

  • Campaign Orders, service selections, Publication options, custom quotes, scope, deliverables and scheduling information;
  • Client and Publication business contacts involved in a Campaign;
  • Client Materials, including text, images, logos, links, claims, briefing materials and approval comments;
  • Campaign communications, revision requests, acceptance or rejection records and delivery confirmations;
  • Account Manager notes and coordination records where a managed service is requested;
  • live URLs, publication dates, impressions, views, clicks and other reasonably available performance or reporting data;
  • complaints, refund, credit, cancellation and dispute-related records; and
  • other information reasonably necessary to administer the requested Publication Campaign.

If Client Materials contain personal data about another person, the Client is responsible for ensuring that it has an appropriate legal basis and has provided any required notices before supplying that data to Influence360 or a Publication.

5.3 Creator Campaign, conversion, Points and referral data

When you participate in Creator Campaigns, Points, referral, leaderboard or related programs, we may process:

  • Campaign type, eligibility rules, applications, accepted deliverables, Content submissions and contribution history;
  • performance, quality, originality, engagement, integrity, fraud and other Campaign-specific scoring signals;
  • Open Creator Campaign submission status, scores, rankings, reward-pool allocation and acceptance or rejection reasons where recorded;
  • Points balances, earning history, multipliers, adjustments, reversals, creator status and other gamification records;
  • referral codes, referrer and referred-account relationships, qualification events and referral attribution;
  • conversion events and status used for Campaign attribution, such as registrations, KYC-completion status, deposits, purchases, wallet connections or other Campaign-specific outcomes. Unless specifically required for a service, Influence360 generally seeks to receive the completion or attribution status rather than underlying KYC documents or financial credentials;
  • tracking-link, referral-code, pixel, server-to-server postback, wallet-attribution and similar measurement identifiers or event data;
  • duplicate-account, self-referral, coordinated-farming, invalid-attribution and other fraud or integrity signals; and
  • Campaign-specific reward, payment or eligibility records.

5.4 Commercial, billing and payment data

For Publication Campaigns and other paid Influence360 services, we may process:

  • legal entity name, billing contact, billing address and country;
  • company or tax registration details, where required for invoicing;
  • invoice numbers, Campaign references, prices, taxes, credits and refunds;
  • payment method type, payment status, transaction reference, settlement date and currency;
  • bank or payment-provider information reasonably necessary to reconcile amounts owed to or by Influence360; and
  • fraud, chargeback or payment-dispute information where applicable.

Where payments are made through a third-party payment processor, full card or bank credential data may be collected directly by that provider rather than by Influence360. We process only the payment information made available to us by the provider and needed for billing, reconciliation, fraud prevention and recordkeeping.

5.5 Wallet and blockchain data

Influence360 may collect public blockchain wallet addresses voluntarily provided by Users and may reference publicly available on-chain data associated with such addresses for attribution, verification, Campaign reporting, conversion measurement or analytics where enabled.

Influence360 does not request User private keys, seed phrases or wallet passwords. The technical architecture of a Campaign may involve User-controlled wallets, smart contracts, multi-signature arrangements or independent providers as described in the Terms of Service; any materially relevant Influence360 technical role should be disclosed in the applicable Campaign documentation.

Public blockchain data may be immutable and outside Influence360's control. We cannot modify, delete or reverse information stored on a public blockchain.

5.6 Social media, analytics and third-party API data

Where Users connect social media, content distribution, attribution or other third-party services, Influence360 may access data made available through authorized APIs or integrations in accordance with the permissions granted by the User and the relevant platform terms. This may include account information, public Content, audience or engagement statistics, Campaign performance metrics, conversion events and related analytics.

We do not intentionally access passwords or other data beyond the scope authorized by the User and permitted by the relevant third-party platform. Private-message access, if ever introduced, would require a specific product need, appropriate permissions and any legally required notice or consent.

5.7 Publicly available and partner-supplied data

Where lawful and relevant to our licensed data classification and analysis functions, we may process publicly available business, social, media, creator, publication, Campaign or on-chain information, or data supplied by authorized partners, vendors, Companies or Publications, to support Campaign reporting, attribution, creator matching, benchmarking, verification, fraud detection, scoring and analytics.

5.8 Technical, device and usage data

  • IP address and approximate location derived from IP;
  • device identifiers;
  • browser type, operating system and application version;
  • access logs, timestamps and session information;
  • pages, features, searches, clicks and interaction events; and
  • security, error and diagnostic logs.

We may use IP, device, geolocation and related metadata to support security, fraud prevention, sanctions screening and geographic eligibility controls. We do not prohibit legitimate use of VPNs merely because a VPN is used, but may investigate technical measures used to circumvent legal or Campaign restrictions.

5.9 Communications and support data

  • support requests and service communications;
  • in-Platform messages between Users;
  • sales, Campaign, Account Manager and Publication communications;
  • legal, compliance and dispute communications; and
  • records of notices, consents, program-rule acceptance and Terms acceptance.

5.10 Sensitive personal data

Influence360 does not intentionally request special-category or sensitive personal data such as health information, biometric identifiers, religious beliefs, political opinions, sexual orientation or similar information, except where strictly necessary and lawful. Users should not include such data in Campaign materials, referral data or Platform messages unless it is genuinely necessary and they have a lawful basis to do so.

6. How We Use Personal Data

We may use personal data to:

  • create, authenticate, administer and secure User accounts;
  • operate, maintain and improve the Platform and its social-media application functionality;
  • provide marketing-management, project-management and Campaign coordination services;
  • administer Awareness, Conversion, Open Creator and other Creator Campaigns;
  • verify Campaign eligibility, attribution and conversions and calculate or administer Campaign-specific rewards;
  • operate Points, referral, leaderboard, creator-status and other promotional or gamification programs, including qualification, earning, ranking, adjustments and fraud controls;
  • operate the Publication Module, including Publication discovery, Campaign administration, custom quotes, Client-Publication communications, order acceptance, delivery coordination and reporting;
  • provide Account Manager assistance requested by Clients;
  • issue invoices, receive amounts payable to Influence360 for its own services, reconcile transactions, process credits or refunds and maintain financial records;
  • interface with smart-contract, wallet, multi-signature or third-party settlement tools where applicable to a Creator Campaign;
  • receive, store, classify, analyze and report Campaign, social, creator, publication, audience, conversion and performance data;
  • provide attribution, benchmarking, scoring, ranking, fraud detection, creator matching, publication recommendations, marketing recommendations and related analytics;
  • prevent self-referrals, duplicate activity, coordinated farming, invalid attribution, fraud, sanctions breaches, abuse and security incidents;
  • handle support, complaints, Campaign issues, disputes and enforcement of contractual rights;
  • comply with tax, accounting, legal, regulatory and law-enforcement obligations;
  • send operational, legal, security and service-related notices;
  • send marketing communications where permitted by law; and
  • protect Influence360, Users, Publications and the integrity of the Platform.

6.1 Aggregated data, analytics and system improvement

Influence360 may create aggregated, anonymized or de-identified information from Platform, Campaign, Points, referral and attribution data and use it for analytics, benchmarking, research, security, product development, service optimization and improvement of automated systems or models. We may use Campaign data and derived performance signals in aggregated or anonymized form to improve scoring models, creator and Publication recommendations, fraud-detection systems, benchmarking, market intelligence, analytics systems and the Influence360 intelligence layer, consistent with applicable data-protection law.

Influence360 does not use identifiable User Content or Client Materials to train public or third-party machine-learning models without appropriate authorization or contractual arrangements. Derived analytical outputs may be retained where lawful for auditability, service integrity, benchmarking or system improvement even if underlying personal data is later deleted or anonymized.

6.2 Automated and AI-assisted scoring and decision-making

Influence360 may use automated systems, analytics, AI-assisted scoring and human review to support Campaign eligibility, contribution scoring, ranking, fraud detection, attribution, creator matching, recommendations, Points administration and Platform security. Scores or automated outputs may influence Campaign ranking, acceptance, reward allocation or program eligibility where the applicable Campaign or program rules disclose that use.

Influence360 does not intend to use solely automated processing to make decisions that produce legal or similarly significant effects outside the relevant Campaign or program context. Where applicable law gives an individual rights in relation to a decision based solely on automated processing, including a right to information, human review or challenge, Influence360 will provide those rights to the extent required by law.

7. Data Sharing and Disclosure

We may disclose personal data only as reasonably necessary for the purposes described in this Policy, including to the following categories of recipients.

7.1 Publications and Campaign counterparties

For a Publication Campaign, we may share with the selected Publication the Client representative's name and business contact details, Campaign Order information, Client Materials, relevant Platform communications, approvals and other information reasonably necessary to review, accept, perform, report on or resolve the Publication Campaign. The Publication may process that information under its own privacy policy and as an independent controller.

For Creator Campaigns, we may share between the relevant Company and Content Creator information reasonably necessary for Campaign participation, performance, attribution, verification, reward administration and dispute handling. For Conversion Campaigns, this may include conversion or qualification status and attribution information, but we aim to avoid sharing unnecessary underlying identity or financial credentials.

7.2 Service providers, processors and attribution providers

We may use third-party providers for cloud hosting, storage, analytics, security, authentication, communications, customer support, compliance, fraud prevention, attribution, conversion measurement, server-to-server postbacks, wallet analytics, document tools and similar operational services. Where required, such providers are subject to contractual confidentiality and data-protection obligations.

7.3 Banks, payment providers and financial administration providers

Where Influence360 invoices or receives payment for its own services, we may disclose billing and transaction information to banks, payment processors, payment gateways, accounting providers, fraud-prevention providers and similar service providers as necessary to process or reconcile the transaction, comply with financial controls or manage refunds and disputes.

7.4 Professional advisers

We may disclose data to lawyers, auditors, accountants, insurers and other professional advisers where reasonably necessary for professional advice, compliance, claims or business administration.

7.5 Legal and regulatory authorities

We may disclose personal data where required by applicable law, court order, subpoena, sanctions obligation, lawful governmental request or where reasonably necessary to establish, exercise or defend legal rights.

7.6 Corporate transactions

We may disclose personal data in connection with a merger, financing, acquisition, restructuring, reorganization, due diligence process or sale of all or part of the business, subject to appropriate safeguards.

7.7 No sale of personal data

Influence360 does not knowingly sell personal data. We do not share personal data for cross-context behavioral advertising as defined by the CCPA. If our practices change, we will update this Policy and provide any legally required opt-out mechanism before the new practice begins.

8. Payment, Billing and Financial-Data Role

8.1 Publication Campaigns and Influence360 service fees

For Publication Campaigns and other paid Influence360 services, Influence360 may issue invoices and receive amounts payable to Influence360 in its own name under the applicable Terms of Service and Campaign Order. We process billing and payment data for invoicing, collection, reconciliation, refunds, accounting, tax and fraud-prevention purposes.

Receiving payment for Influence360's own contracted services does not mean that Influence360 acts as a payment institution, money transmitter, payment aggregator, trustee or custodian for Publications or other Users. Where a bank or third-party payment provider processes a payment, that provider may independently process personal data under its own privacy notice.

8.2 Creator Campaign settlement and digital assets

Influence360 does not hold User digital assets in a traditional custodial account. Creator Campaign settlement may rely on smart contracts, multi-signature wallets, User-controlled wallets or independent third-party providers. The specific technical roles, signing authorities and release mechanics may vary by Campaign architecture and are governed by the applicable Terms of Service and Campaign-specific disclosures. Influence360 may process wallet addresses, transaction identifiers, settlement status and related technical data where reasonably necessary for Campaign administration, attribution, compliance, fraud prevention or support.

9. Crypto, Wallets and Blockchain-Specific Disclosure

If you use blockchain-related features, you acknowledge that blockchain transactions and wallet addresses may be public, permanent and linkable to other activity. Blockchain networks are outside Influence360's control and data recorded on-chain may not be capable of deletion or modification.

10. Data Security

We implement reasonable administrative, technical and organizational safeguards designed to protect personal data against unauthorized access, loss, misuse, alteration or disclosure. Measures may include encryption in transit and, where appropriate, at rest; access controls; authentication; logging; monitoring; backups; vendor controls; and incident-response procedures.

No online service is completely secure. Users are responsible for protecting their account credentials, devices and connected third-party accounts.

11. Personal Data Breaches and Security Incidents

Influence360 maintains procedures to assess and respond to suspected personal data breaches or security incidents. Where applicable law requires notification to an affected individual, regulator or other authority, we will make the notification in accordance with the applicable legal requirements.

12. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to provide the Platform and Campaign services, administer Points and referral programs, maintain attribution, fraud-prevention and audit trails, comply with tax and accounting obligations, resolve disputes, enforce agreements and establish or defend legal claims.

Retention periods may differ by data category. For example, account, Campaign, Points, referral and attribution records may be retained while an account or relevant program is active and for a reasonable period afterward; invoice, payment and tax records may be retained for legally required periods; and security logs may be retained for shorter operational periods unless needed for an investigation. Public blockchain data may persist indefinitely because Influence360 does not control the blockchain.

Where data is no longer required, we will delete, anonymize or securely isolate it as appropriate and subject to applicable law.

13. Your Privacy Rights

Depending on where you live and the law that applies, you may have rights to:

  • request access to personal data we hold about you;
  • request correction of inaccurate or incomplete data;
  • request deletion, subject to legal exceptions;
  • restrict or object to certain processing;
  • request portability of certain data;
  • withdraw consent where processing is based on consent;
  • object to or obtain information about certain automated decision-making or profiling;
  • opt out of certain targeted advertising, sale or sharing where applicable;
  • appeal certain privacy-request decisions where applicable; and
  • lodge a complaint with a competent privacy or data-protection authority.

13.1 California and certain U.S. state rights

Where the CCPA or another U.S. state privacy law applies, eligible individuals may have rights to know or access categories or specific pieces of personal information, delete information subject to exceptions, correct inaccurate information, opt out of sale or certain sharing or targeted advertising, limit certain uses of sensitive personal information, and exercise rights without unlawful discrimination. Influence360 does not currently sell personal information or share it for cross-context behavioral advertising as defined by the CCPA.

13.2 Verification and authorized agents

We may take reasonable steps to verify your identity before fulfilling a request. Where permitted by law, an authorized agent may submit a request on your behalf, but we may request proof of authorization or direct confirmation from you.

13.3 Controller/processor limitation

If Influence360 processes specific personal data solely as a processor on behalf of a Company or another controller, we may refer your request to that controller or assist it in responding, as required by applicable law and contract.

13.4 How to exercise rights

Privacy requests may be submitted to support@influence360.io. Please provide enough information for us to identify the relevant account or data and understand your request. We will respond within the timeframe required by applicable law.

14. International Data Transfers

Influence360 is established in the United Arab Emirates and may use service providers, Publications, Companies, attribution providers, Users or infrastructure located in other countries. Personal data may therefore be transferred to, accessed from or processed in jurisdictions outside your country of residence.

Where applicable law requires transfer safeguards, we will use appropriate mechanisms such as contractual safeguards, adequacy mechanisms, transfer assessments or other legally recognized measures. Different countries may provide different levels of data protection.

15. Cookies, Pixels and Similar Technologies

We may use cookies, local storage, pixels, SDKs, tracking links and similar technologies for essential Platform operation, authentication, security, fraud prevention, preferences, analytics, Campaign attribution, conversion measurement and performance monitoring.

Where required by applicable law, non-essential cookies, pixels or similar technologies will be used only after appropriate consent. Users may manage available preferences through our consent tools or browser settings. Disabling certain technologies may limit Platform functionality, Campaign attribution or eligibility for conversion-based rewards where the relevant tracking is necessary to verify the Campaign event.

16. Marketing Communications

Influence360 may send marketing or promotional communications where permitted by law. You may opt out using the unsubscribe mechanism in the message or by contacting us. Operational, transactional, security, legal, Campaign, Points, referral and program communications are not marketing messages and may still be sent where necessary to provide the service, administer participation or comply with law.

17. Third-Party Services, Publications and External Websites

The Platform may integrate with or link to third-party websites, social networks, Publications, payment providers, attribution providers, KYC or verification providers, analytics providers, blockchains or other services. Those third parties may independently collect or process personal data under their own privacy notices and terms.

Influence360 is not responsible for the independent privacy practices of a Publication or other third party. Users should review the applicable third-party privacy notice when interacting with that service.

18. Children's Privacy

The Platform is intended for individuals aged 18 or older. Influence360 does not knowingly collect personal data from children. If we learn that personal data of a child has been collected without an appropriate legal basis, we will take reasonable steps to delete it.

19. Data Protection by Design and Data Minimization

Influence360 aims to collect and process personal data that is reasonably necessary for the relevant Platform function, Campaign, Points or referral program, security purpose, contractual service or legal obligation. We may apply access restrictions, role-based permissions, aggregation, anonymization, pseudonymization or other measures to reduce unnecessary exposure of personal data.

20. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in law, Platform functionality, Campaign models, Points or referral programs, service providers or business practices. Material changes will be communicated through the Platform, email or another appropriate method where required by law. The effective date at the top indicates when the current version applies.

21. Contact Information

For privacy questions, rights requests or data-protection concerns:

Email: support@influence360.io

Data Controller: Influence360 - F.Z.C

Licence / Registration No.: 41123

Registered Address: Office - C1 - 1F - SF5820, Ajman Free Zone C1 Building, Ajman, United Arab Emirates

If applicable law requires a local representative, data protection officer or additional privacy contact for a particular jurisdiction, Influence360 may publish or provide those details separately.

22. Governing Law and Mandatory Privacy Rights

This Privacy Policy is governed by the laws of the United Arab Emirates as applicable in the Emirate of Ajman, without prejudice to mandatory privacy or data-protection rights that apply to you under another applicable law.