Privacy Policy

1. Who We Are

Collabee ("Collabee", "we", "us", "our") operates an online marketplace connecting Brands with UGC creators, models and product photographers.

For the purposes of applicable UK data protection law, Collabee is the controller of personal information described in this Privacy Policy where we determine how and why that information is processed.

Website: www.collabeeugc.com
Email: hello@collabee.co.uk

If you have questions about this Privacy Policy or how we use your personal information, please contact us using the details above.

2. Personal Information We Collect

The information we collect depends on whether you use Collabee as a Creator, Brand or website visitor and which features you use.

2.1 Account Information

When you create or manage an account, we may collect:

• name;
• email address;
• account type;
• login and authentication information;
• account status;
• country or location information; and
• information you provide when communicating with us about your account.

Passwords are stored using appropriate secure authentication/hashing processes and are not stored by us in readable plain text.

2.2 Creator Profile Information

Creators may provide information used to create their Collabee profile, including:

• display name;
• profile photograph;
• country and location;
• biography;
• social media information;
• Creator type;
• content types offered;
• experience level;
• availability;
• rates;
• portfolio photographs and videos;
• video introduction; and
• other information voluntarily added to a profile.

Depending on the services a Creator offers, this may also include profile characteristics useful to Brands when searching for appropriate talent, such as:

• age range;
• gender;
• height;
• hair colour;
• hair length;
• eye colour;
• skin tone;
• clothing size; and
• other relevant characteristics made available through the Platform.

Creators choose the information they provide, subject to any information Collabee requires to operate a particular feature.

2.3 Brand Information

Where you use Collabee as a Brand, we may collect:

• your name;
• business or Brand name;
• business contact details;
• billing information;
• Commission Requests;
• Briefs;
• information about products or services;
• Creator search and selection information; and
• other information supplied in connection with a Booking.

2.4 Commission and Booking Information

When Brands and Creators use Collabee to arrange or manage work, we may collect and retain information relating to the Commission, including:

• Commission Requests;
• Briefs and project requirements;
• acceptance or decline information;
• agreed Creator Rates;
• Booking status;
• deadlines;
• messages between Brands and Creators;
• Content submitted through the Platform;
• Revision requests;
• approval information;
• cancellation information;
• disputes;
• refunds; and
• records relating to Creator payouts.

2.5 Communications

We may collect communications including:

• messages sent through Collabee;
• contact-form enquiries;
• customer-support correspondence;
• emails sent to us; and
• communications concerning Bookings, disputes or account issues.

Where Collabee provides messaging functionality, messages may be stored and accessed where reasonably necessary to operate the service, investigate reports, resolve disputes, prevent fraud or comply with legal obligations.

2.6 Payment and Transaction Information

Brand payments may be processed through third-party payment providers such as Stripe.

Creator payouts may be made using third-party payout providers such as PayPal.

Collabee does not ordinarily receive or store complete payment-card details. These are handled by the relevant payment provider.

We may nevertheless receive and retain information relating to transactions, including:

• payment amount;
• Creator Rate;
• Collabee booking fee;
• currency;
• transaction date;
• payment status;
• refund information;
• payment-provider transaction identifiers;
• payout status; and
• information reasonably required for accounting, fraud prevention, dispute resolution or legal compliance.

Creators may also provide information necessary to enable us or our payment providers to make payouts.

2.7 Technical and Usage Information

When you use Collabee, we may automatically collect information such as:

• IP address;
• browser type;
• device type;
• operating system;
• pages viewed;
• date and time of access;
• referring website or source;
• interactions with Platform features;
• search activity and filters;
• log information; and
• technical error and security information.

Some of this information may be collected through cookies and similar technologies. See our Cookie Policy for further information.

3. How and Why We Use Your Information

We use personal information only where we have an appropriate lawful basis.

Purpose	Lawful basis
Creating and administering your Collabee account	Performance of a contract
Providing Collabee's marketplace features	Performance of a contract
Publishing Creator profiles and portfolios	Performance of a contract
Allowing Brands to search for and discover Creators	Performance of a contract / legitimate interests
Processing Commission Requests and Bookings	Performance of a contract
Processing Brand payments and Creator payouts	Performance of a contract / legal obligation
Facilitating Brand-Creator communications	Performance of a contract
Resolving disputes, cancellations and refunds	Performance of a contract / legitimate interests
Preventing fraud, misuse and circumvention of the Platform	Legitimate interests / legal obligation where applicable
Maintaining Platform security	Legitimate interests / legal obligation where applicable
Improving and analysing Collabee	Legitimate interests
Maintaining business, tax and accounting records	Legal obligation / legitimate interests
Responding to enquiries and support requests	Performance of a contract / legitimate interests
Sending marketing communications where consent is required	Consent
Complying with legal or regulatory requirements	Legal obligation

Where we rely on legitimate interests, those interests include operating, protecting and improving Collabee; preventing fraud and misuse; resolving disputes; understanding how the Platform is used; protecting our marketplace and users; and administering our business.

We consider the impact of this processing on individuals and do not rely on legitimate interests where our interests are overridden by your rights and interests.

4. Creator Profile Visibility

Collabee is designed to enable Brands to discover Creators.

When a Creator publishes a profile, information intended to form part of that profile may be visible to Brands and, depending on the relevant Platform feature and privacy setting, other visitors to Collabee.

This may include:

• display name;
• profile photograph;
• country/location;
• biography;
• Creator and content types;
• experience level;
• availability;
• rates;
• portfolio photographs and videos;
• video introduction; and
• profile characteristics the Creator has chosen to provide for Brand discovery.

We do not display a Creator's private account email address as part of their public Creator profile.

Brands should communicate with Creators using the communication tools provided or authorised by Collabee.

Creators should not upload sensitive information to their public profile that they do not want Brands or other permitted viewers to see.

5. Who We Share Information With

We do not sell your personal information.

We may disclose information where reasonably necessary to the following categories of recipients:

Other Collabee Users

Creator profile information is made available to Brands as described above.

Information relating to a Booking may be shared between the relevant Brand and Creator as necessary to arrange and complete the Commission.

Payment and Payout Providers

We may share necessary information with payment providers including Stripe for Brand payments and PayPal or other supported providers for Creator payouts.

These providers may process certain information as independent controllers under their own privacy policies as well as, where applicable, on our behalf.

Hosting and Technology Providers

We may use third-party providers for website hosting, databases, cloud infrastructure, authentication, communications, email delivery, security and other technical services.

Analytics Providers

We may use analytics services to understand how Collabee is used and improve the Platform.

Where reasonably possible, we limit, aggregate or pseudonymise information used for analytics.

Professional Advisers

Information may be shared where reasonably necessary with accountants, lawyers, insurers or other professional advisers.

Authorities and Legal Recipients

We may disclose information where required by law, court order, regulator or other competent authority, or where reasonably necessary to establish, exercise or defend legal rights.

Business Transfers

If Collabee or substantially all of its business or assets is sold, reorganised or transferred, personal information may be disclosed to relevant advisers, prospective purchasers and the acquiring organisation, subject to appropriate safeguards.

6. Data Retention

We keep personal information only for as long as reasonably necessary for the purposes for which it was collected and to meet applicable legal, accounting, tax, fraud-prevention and dispute-resolution requirements.

Generally:

• Active accounts: account and profile information is retained while the account remains active and as necessary to provide Collabee.
• Creator profiles: when a Creator deletes or closes their account, their public profile will be removed from public availability within a reasonable operational period.
• Transaction and Booking records: information required for accounting, tax, payment, chargeback, fraud prevention, legal or dispute-resolution purposes may be retained after account closure. Certain financial and business records may be retained for up to 7 years where reasonably necessary.
• Communications and disputes: correspondence and records relating to complaints, disputes or legal matters may be retained for as long as reasonably necessary to resolve the matter and establish or defend legal rights.
• Marketing: where you withdraw consent or unsubscribe, we will stop sending the relevant marketing and may retain limited information on a suppression list so that we can respect your preference in future.

Account deletion therefore does not necessarily result in the immediate deletion of every record associated with the account.

7. Marketing Communications

Where required, we will send marketing communications only where you have consented to receive them.

You may unsubscribe at any time using the unsubscribe link contained in a marketing email or by contacting us.

Withdrawing consent does not affect the lawfulness of processing that took place before consent was withdrawn.

Service messages concerning your account, Commission Requests, Bookings, payments, security or other essential Platform matters are not marketing messages and may still be sent where necessary to provide Collabee.

8. Your Data Protection Rights

Depending on the circumstances and the lawful basis on which we process your information, you may have rights including:

• access — to request a copy of personal information we hold about you;
• rectification — to ask us to correct inaccurate or incomplete information;
• erasure — to request deletion in circumstances where the right applies;
• restriction — to ask us to restrict certain processing;
• data portability — to receive certain information in a structured, commonly used and machine-readable format;
• objection — to object to certain processing, including processing based on legitimate interests; and
• withdrawal of consent — where processing is based on consent.

You also have an absolute right to object to the use of your personal information for direct marketing.

Collabee does not currently use solely automated decision-making that produces legal or similarly significant effects about users.

To exercise your rights, contact hello@collabee.co.uk.

We will normally respond without undue delay and within one month, subject to any lawful extension or exception.

We may request information reasonably necessary to verify your identity before responding.

You will not ordinarily be charged for exercising your rights, although applicable law permits fees or refusal in certain circumstances involving manifestly unfounded or excessive requests.

9. Complaints

If you have concerns about our use of your personal information, please contact us first so that we can investigate.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator.

ICO: ico.org.uk
Telephone: 0303 123 1113

10. Cookies

We use cookies and similar technologies to operate Collabee and, where applicable, understand how the Platform is used.

Some cookies are necessary for the Platform to function. Other cookies may require your consent.

Please see our Cookie Policy for information about the cookies and similar technologies we use and the choices available to you.

11. Security

We use appropriate technical and organisational measures designed to protect personal information.

Depending on the systems involved, these may include:

• encrypted connections;
• secure password handling;
• access controls;
• restricted administrative access;
• security monitoring; and
• appropriate safeguards provided by our technology suppliers.

No internet-based service can guarantee absolute security.

If a personal data breach occurs, we will assess it in accordance with applicable data protection law.

Where legally required, we will notify the ICO without undue delay and, where feasible, within 72 hours of becoming aware of the breach.

Where a breach is likely to result in a high risk to affected individuals' rights and freedoms, we will also notify those individuals without undue delay.

12. International Data Transfers

Collabee may use service providers that process personal information in countries outside the United Kingdom.

Where personal information is transferred internationally, we take steps required by applicable UK data protection law to ensure that the transfer is lawful.

Depending on the destination and recipient, this may include relying on:

• UK adequacy regulations;
• the UK International Data Transfer Agreement (IDTA);
• the UK Addendum to approved EU Standard Contractual Clauses; or
• another lawful transfer mechanism or exception.

Where required, we also assess whether additional safeguards are necessary.

You may contact us at hello@collabee.co.uk if you would like further information about safeguards applying to relevant international transfers.

13. Children's Privacy

Collabee is intended only for users aged 18 or over.

We do not knowingly permit anyone under 18 to create an account.

If we become aware that an account has been created by someone under 18, we may close the account and take reasonable steps to delete or restrict the associated personal information, subject to legal retention requirements.

If you believe a person under 18 has created an account, please contact hello@collabee.co.uk.

14. Changes to This Privacy Policy

We may update this Privacy Policy where our services, processing activities or legal obligations change.

The latest version will be published on Collabee with the "Last updated" date shown at the top.

Where a change materially affects how we use personal information, we will take reasonable steps to bring the change to affected users' attention and, where required by law, obtain consent.

15. Contact Us

For questions about this Privacy Policy or to exercise your data protection rights, please contact:

• Email: hello@collabee.co.uk
• Website: www.collabeeugc.com

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