Introduction

This Privacy Policy outlines how Tokko Labs, Inc. ("Clero", "we", "us") collects, uses, and discloses personal information of Creators – i.e., users who create or contribute content (such as influencers, videographers, designers, etc.) on the Clero platform. By using Clero as a Creator, you consent to the practices described in this policy. Tokko Labs, Inc. is the controller of your personal data processed via Clero's creator services.

Information We Collect

We collect several categories of personal data from Creator users:

- Profile Information: When you register as a Creator on Clero, we collect information like your name, email address, phone number, date of birth (if provided), login credentials, and profile image (avatar). You may also provide a display username, a bio or description of your creative services, and links to your social media accounts or portfolio. We collect any fields you fill in on your creator profile. - Social Media and Content Data: Clero may request access to or information about your social media presence if relevant to our platform. For example, you might link your Instagram, YouTube, TikTok, or other social handles to your Clero profile. If you do so, we may collect data such as your username on those platforms, follower counts, engagement metrics, and content performance stats, to the extent you authorize. We do not collect your social media login credentials (you would authorize via those platforms' OAuth flows). Additionally, as a content creator, you will likely upload content to Clero (photos, videos, graphics, text) as part of projects. We collect and store that content, including any metadata in the files. - Financial Information: To facilitate payments to you, we collect payment-related information. This might include your bank account details or PayPal email for payouts, tax identification details (like a W-9 form for US creators or equivalent for others), and mailing address (for invoicing or tax forms). Payment processing is handled through secure third-party providers (e.g., Stripe, PayPal) – we store only what is needed to identify your account for payout and comply with tax laws. Financial info such as credit card or bank routing numbers are stored by the payment processor, not by Clero, whenever possible. - Usage and Device Data: We automatically collect data about how Creator users access and use the platform. This includes technical info like IP address, device identifiers, browser type, operating system, and interaction logs (dates/times of logins, pages viewed, clicks, errors). If you use a mobile app (if Clero provides one), we may collect device identifiers and telemetry (such as app version and crashes). We also use cookies and similar technologies to track sessions and preferences. Some of this data is collected via third-party analytics (e.g., Google Analytics) to help us improve the service. - Communications: We collect content of communications on the platform, such as messages or chat with Brands or with our support. If you communicate with us via email or other channels, we collect those communications. We may also record customer support calls with your consent (if we inform you). Additionally, we might ask for feedback or survey responses from you to improve our platform, which we would collect if you choose to provide.

How We Use Your Information

We use Creator personal data for the following purposes:

- Providing the Service: Primarily, we use your information to operate Clero's creator marketplace and facilitate your collaborations with Brands. This includes displaying your Creator profile (name, bio, social stats, portfolio content) to Brands searching for creators, recommending you for relevant campaigns, and allowing you to apply to or be invited to Brand projects. We use your contact info to maintain your account and contact you about project opportunities or updates. If you upload content or link social media, we use that to showcase your work to Brands and measure campaign deliverables. We also use your bank/payments info to send you earnings for completed projects. - Matching and Personalization: Clero may use algorithms (and sometimes our team's input) to match creators with suitable brands/campaigns. We may analyze your profile information, content categories, and performance metrics to suggest you to Brands or vice versa. This is to improve the chances of successful partnerships. - Payments and Accounting: We process your personal and financial data to pay you for your work. For example, after you complete a campaign, we will use your payout information to issue payment via our payment provider. We also use your data to generate any required tax documents (such as 1099 forms for U.S. creators earning above certain thresholds) and to maintain proper financial records. - Communications: We use your email or other contact info to send service-related communications, such as notifications of new project invitations, messages from Brands, updates on payment status, or changes to our terms. We may also send you marketing or newsletter emails about platform features or creator opportunities, but only if you haven't opted out. You can unsubscribe from promotional communications at any time. (Note: transactional emails about your projects or account are not optional.) - Platform Improvement and Research: We analyze usage data and feedback to improve Clero's functionality and user experience. For example, we might analyze how many proposals you send versus accepted, or how quickly files load, etc., to optimize the platform for creators. We use analytics tools like Google Analytics to understand overall behavior on our site. We may also aggregate data to research trends (e.g., average earnings, popular content types) – aggregated data will not identify you personally. - Safety and Integrity: We process personal data as needed to enforce our Terms of Service and community guidelines. This includes monitoring for fraudulent activities or content violations. For instance, we may review communications on the platform to investigate a reported harassment incident or use automated tools to detect plagiarism or prohibited content in uploads. If you are involved in a dispute or if we suspect improper conduct, we will use relevant data (messages, profile info, IP logs) to resolve it. We also may use your data to comply with legal obligations, such as verifying identity for anti-fraud or sanctions compliance, or handling lawful information requests.

How We Share Your Information

Clero will share Creator information only in the ways described below, ensuring appropriate safeguards. We do not sell creators' personal data to third parties for their own marketing.

- With Brands (Client Users): Sharing data with Brands is fundamental to the service. When you apply to or are active in a Brand's campaign, that Brand will see information from your profile that is relevant to the collaboration. This includes your display name or real name (depending on what you choose to show), your profile picture, bio, location (if provided at least in general region), and portfolio content or statistics on your prior work. Brands will also see any content you submit for their campaign, obviously. They may also see certain communication details (like if you respond to messages). We do not share your personal contact info (email, phone) with Brands through the platform – all communication should occur via Clero's messaging system for your safety. (If a particular campaign necessitates direct contact, you can choose to share info with the Brand, but do so at your discretion.) If a Brand needs to ship you a product for a campaign, you may provide an address through Clero, which we will pass to the Brand. Use caution and only provide what is necessary. - With Our Internal Team (Makers/Staff): Our Makers (Tokko Labs employees/contractors) and support staff will have access to your information as needed to assist with projects. For example, a Maker (producer/editor on our side) may view your content submissions to help refine them or ensure they meet Brand standards. Staff handling payments will access your payout details to process transactions. All such personnel are bound by confidentiality and data security commitments. - Service Providers and Partners: We use third-party companies to help us run Clero, and we share data with them under strict contracts. Examples include: cloud hosting providers (for data storage and servers on AWS), database and IT support services, payment processors (to send you money – e.g., Stripe or banking partners will receive your name and banking details to execute payments), analytics services (like Google Analytics – which will collect usage data via cookies/tracking scripts), email service providers (to send notifications), and AI or content tools (e.g., if we use an AI platform to help generate or edit content, we may upload your images/videos to that tool to produce the result). These third parties are authorized to use your data only as necessary to provide services to us and are contractually obligated to protect it. For example, if we use an AI video editing service, we would share the raw video content and any instructions needed for editing. Such providers are not allowed to retain or use your content to train their models or for purposes outside our request. We ensure our vendors follow applicable privacy laws and best practices. We never share more data than required – e.g., our analytics providers primarily see aggregated or pseudonymous data. - Public Display: Certain creator information may be publicly visible on our platform or marketing materials. For instance, if Clero has a public directory of creators, your profile (minus sensitive info) might be viewable by visitors or potential clients. Also, if we highlight success stories or examples of creator work on our site or social media, we may display your username, profile photo, and some of your content (with attribution to you). We will not expose your personal contact details publicly without consent. If you prefer to stay unlisted publicly, check your settings or let us know – however, basic profile visibility to logged-in Brands is intrinsic to using Clero as a marketplace. - Legal and Compliance: We may disclose creator personal data when required by law or valid legal process, or to establish or exercise our legal rights. For example, if we receive a subpoena, court order, or government demand requiring us to disclose data (such as details of earnings for tax enforcement, or communications for an investigation), we'll comply to the extent legally obligated. We might also share information if we believe it is necessary to investigate or take action regarding illegal activities, suspected fraud, threats to personal safety, or violations of our Terms. We will notify you of such disclosure when allowed, in order to be transparent. Additionally, if you are paid above certain thresholds, we must share your earnings and tax info with taxing authorities as required by law. - Business Transfers: In the event Tokko Labs, Inc. engages in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets, your personal data may be transferred to a successor or affiliated entity as part of that transaction. We will ensure the new owner honors the commitments we have made in this Privacy Policy or provide notice and choices if data practices change.

We emphasize that we never sell or rent your personal data. Any third-party processing is solely to support our service to you. We also do not share your content or personal info with Brands or others outside the Clero platform context without permission. For instance, we won't give your email to another user; communications remain in-app unless you choose otherwise.

Data Storage and International Transfers

Clero stores Creator data primarily on AWS servers in the United States. If you reside outside the U.S., your data will be transferred to and processed in the U.S. (where our operations and personnel are located). The U.S. may not have the same data protection laws as your home jurisdiction, but we take steps to safeguard cross-border data transfers. For example, for EU/UK creators, we rely on standard contractual clauses or other appropriate safeguards to legitimize the transfer. By using Clero, you understand that your information will be sent to the U.S. and you consent to that transfer, as needed for us to provide the service. We maintain data handling practices in line with EU GDPR principles even for data we handle in the U.S. All data is stored securely; our databases and file storage use encryption at rest and in transit. We operate a robust security program (access controls, monitoring, etc.) to prevent unauthorized access.

Data Security

We protect Creator data with a combination of technical and organizational security measures. This includes encryption (e.g., HTTPS encryption for data in transit), regular security audits, network firewalls, and secure access procedures. Only authorized staff and contractors with a need-to-know can access personal data, and they are all subject to confidentiality obligations. We also encourage you as a user to practice good security (choose a strong password, enable two-factor authentication if available, and guard your login credentials). Despite our efforts, no online platform can guarantee 100% security. You acknowledge that there is some risk in transmitting data over the internet, but we do our best to mitigate this. In the unlikely event of a data breach affecting your personal data, we will notify you and take steps to remediate, in accordance with applicable laws.

Data Retention

We retain Creator personal data only as long as necessary for the purposes described. In general, as long as you have an active Creator account, we will keep your profile information and content so that you can continue to use the platform. If you decide to delete your account, we will remove or anonymize your personal data within a reasonable period, except for data we are required or permitted to keep longer. For example, we may retain records of payments to you for several years to comply with tax and accounting obligations. If you participated in a campaign, we might retain the deliverables for the Brand's use and our records, but we would disassociate it from your identity upon your request when feasible. Communication records or support tickets might be kept to defend against potential legal claims or to analyze and improve services. We also retain backups for a limited time. When determining retention periods, we consider factors like the nature of the data, the purposes of processing, our contractual obligations to Brands (e.g., keeping campaign history), and legal requirements. When data is no longer needed, we will either delete it or anonymize it. We may use aggregated data derived from your personal data (which no longer identifies you) indefinitely for research and business analytics.

Your Rights as a Creator

We respect that you have rights over your personal information. Depending on your jurisdiction, your rights may include:

- Access: You can request a copy of personal data we hold about you and information on how we use it. Much of your basic info is accessible through your account (profile, settings, etc.), but you can contact us for a full report. - Correction: You have the right to correct or update inaccurate or incomplete personal data. You can edit many details in your profile directly. If you need something changed that you cannot edit, reach out to us. - Deletion: You may request deletion of your personal data. For example, if you no longer wish to use Clero, you can ask us to delete your account. We will comply, except for information we must keep for legitimate reasons (as noted in Data Retention). If you have ongoing projects, we might need to keep your account active until those are concluded or ensure a proper handover. - Objection/Opt-Out: You can object to certain processing or opt out of marketing emails (as described earlier). For instance, you can opt out of any direct marketing by using the unsubscribe link or contacting us. If you object to a specific use of data that you consider not justified, we will evaluate and comply unless we have compelling legitimate grounds or it's needed for legal claims. - Portability: In some cases, you can request a copy of data you provided to us in a machine-readable format (for example, a CSV of your profile information and campaign history) so you can reuse it elsewhere. - Non-Discrimination: We will not treat you differently for exercising any privacy rights.

To exercise any rights, please contact us at the details below. We will verify your identity (to protect privacy) and respond within the timeframe required by law (typically within 30 days for most requests). Some requests may be denied if they conflict with legal obligations or others' rights; we'll explain the reasoning if so. For example, if a Brand has a legal license to content you created under a campaign, we cannot delete that content from the Brand's account upon your request, but we can remove personal identifiers from our records of it.

If you are in the EU or UK and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your data protection supervisory authority. For example, in the UK that would be the ICO.

Children's Privacy

Clero's creator services are not intended for use by individuals under 13 years of age. We do not knowingly collect personal data from children under 13. If you are under 18 but at least 13, you may join as a Creator *only with* the involvement and consent of a parent or guardian. Creating content partnerships often involves legal agreements, so minors should have a legal guardian review terms. We adhere to COPPA and similar laws; if we discover a Creator account is managed by a child under 13 without parental consent, we will terminate the account and delete any associated personal data. If you are a parent/guardian of a Creator under 18, we encourage you to supervise their activities on Clero. For minors, we may require a parent or guardian to co-sign agreements or payment setups. By using Clero as a Creator, you affirm that you meet these age requirements.

Cookies and Tracking

Clero uses cookies and similar tracking technologies on our website to personalize content, remember settings, and analyze usage. For example, cookies allow us to keep you logged in and track your navigation so we can understand what pages are popular. Third parties like Google Analytics set their own cookies to provide analytics services. You have choices in managing cookies: you can set your browser to refuse certain cookies or to alert you when cookies are being used. However, note that if you disable cookies, some features of Clero might not function properly (like staying logged in). We honor any applicable "Do Not Track" signals to the extent required by law. For more details, see our Cookie Notice (if provided) or reach out to us.

Changes to this Policy

We may update this Creator Privacy Policy from time to time. Material changes will be communicated to you (e.g., via email or prominent notice on our site) prior to the change taking effect. The "Effective Date" at the top will indicate when the latest changes were made. Your continued use of Clero as a Creator after we make changes indicates acceptance of the updated policy. If you do not agree with any update, you should stop using the platform and may request deletion of your data.

Contact Us

If you have questions or concerns about this Privacy Policy or your personal data, please contact us:

- Tokko Labs, Inc. - Email: support@clero.com

We're here to help and will address your inquiry as soon as possible, typically within a few business days. Your privacy is important to us, and we welcome feedback on how we can better protect and honor your data rights.