1. Scope of This Privacy Policy

This Privacy Policy describes how Influency, Inc. (the “Company,” “Influency,” “we,” “us,” or “our”) collects, uses, discloses, stores, and otherwise processes personal information in connection with the My Influency platform, including the application located at www.myinfluency.com and https://app.myinfluency.com, as well as any successor websites, subdomains, sub-sites, mobile applications, and related services that reference this Privacy Policy (collectively, the “Services”).

This Privacy Policy applies to personal information collected through the Services, including information collected when you create an account, use campaign and workspace features, communicate with us or other Users through the Services, connect third-party platforms, make or receive payments through platform workflows, subscribe to a paid plan, or otherwise interact with the Services.

This Privacy Policy should be read together with our Terms of Service and any applicable Additional Terms. Capitalized terms not defined in this Privacy Policy have the meanings assigned to them in the Terms of Service.

By accessing or using the Services, you acknowledge that your personal information will be handled as described in this Privacy Policy.

2. Categories of Information We Collect

We may collect personal information and other information about you from a variety of sources, depending on how you interact with the Services.

2.1 Information You Provide Directly

We collect information you provide to us directly in connection with your use of the Services, including when you create an Account, complete a Profile, subscribe to a plan, create or join a workspace, submit a proposal, participate in a campaign, connect a social media account, make a payment, contact support, submit a dispute or claim, respond to communications, or otherwise use the Services.

Such information may include your name, email address, phone number, account credentials, profile information, business or agency information, workspace information, billing information, communications, campaign information, proposal information, and any other information you choose to provide through the Services.

2.2 Account, Profile, and User Type Information

We collect information relating to your registration and role on the platform, including whether you use the Services as a Brand, Agency, Influencer, workspace administrator, team member, billing contact, or other authorized user.

We may also collect Profile information, including business details, represented clients, social handles, portfolio content, settings, preferences, and other Profile Content made available through the Services.

2.3 Workspace and Organization Information

Where the Services support workspace, organization, or multi-user account structures, we may collect information relating to workspace creation, user invitations, membership, roles, permissions, administrative actions, team activity, settings, subscription ownership, billing contacts, and communications made available within a workspace.

Information within a workspace may be visible to other authorized users within that workspace, depending on applicable roles and permissions.

2.4 Campaign, Proposal, Agreement, and Deliverable Information

We collect information relating to campaigns, proposals, deliverables, agreements, and related activity conducted through the Services. Such information may include campaign descriptions, proposal terms, deadlines, deliverables, compensation structure, usage rights, content submissions, status changes, communications between Users, supporting documentation, and related operational records.

Because the Services facilitate coordination between Users, information submitted in connection with campaigns and proposals may be shared with relevant Users as part of the core functionality of the Services.

2.5 Subscription, Billing, and Payment Information

If you purchase a subscription, authorize a payment, or participate in a transaction through the Services, we may collect billing and transaction-related information, including subscription status, billing contact information, plan details, transaction dates, transaction amounts, payment status, invoice and receipt data, refund or adjustment data, and related usage records.

Payments are generally processed through third-party payment processors, such as Stripe. We do not typically store full payment card numbers or full bank account information.

2.6 Dispute, Claim, and Support Information

We may collect information submitted in connection with disputes, claims, support requests, customer service interactions, moderation reviews, enforcement actions, or other issue-resolution processes. Such information may include supporting evidence, correspondence, timestamps, transaction history, communications between Users, and internal resolution records.

2.7 Social Media and Third-Party Platform Information

When you connect a third-party platform to your Account — including a Meta-owned platform such as Facebook, Instagram, Instagram Business, Instagram Creator, or the Instagram Creator Marketplace (“ICM”) — we collect and process information made available to us by that platform in accordance with your authorization, the platform’s policies, and applicable law.

2.7.1 Profile, Audience, and Performance Data

Subject to the permissions you grant, we may collect from connected Meta platforms information such as account identifiers, usernames, profile information, the list of pages you administer, connected content (including posts and reels), audience and follower information, engagement metrics, reach and impressions, content performance metrics, demographic insights, and similar social or analytics data. We use this information to operate features of the Services that depend on the connection, including campaign matching, deliverable verification, performance reporting, and ICM-related workflows.

2.7.2 Authentication Tokens and Permissions

To maintain your connection and perform the actions you have authorized on a connected Meta platform, we collect and store, in encrypted form, the credentials and identifiers Meta issues to us. These may include short-lived and long-lived user access tokens, page access tokens, your Instagram account identifier, your Facebook App-scoped user identifier, the page identifier associated with your Account, the specific permissions (scopes) you granted, the dates the tokens were issued and most recently refreshed, and any reason the tokens were last invalidated or revoked. We request only the Meta permissions reasonably necessary to provide the features you use. The specific permissions are presented to you by Meta at the time you authorize the connection, and you may review the active permissions in your Meta account settings at any time.

2.7.3 Token Refresh, Retention, and Revocation

Access tokens are retained for as long as your Meta connection remains active and may be automatically refreshed by our systems in accordance with Meta’s token-refresh procedures so that we can continue to perform the actions you authorized without requiring you to re-authenticate. We log token-related errors (for example, expired, invalid, or revoked tokens) for the limited purpose of diagnosing connection issues and notifying you when reconnection is required. When you disconnect a Meta-linked account, when Meta revokes the tokens, or when your Account is deleted, we delete the associated tokens promptly. You may also disconnect a Meta platform at any time through your Account Settings or by revoking our application’s access in your Meta account settings. Additionally, in accordance with Meta’s Data Deletion Callback requirements, we honor data-deletion requests initiated through Meta’s platform and process them through our internal deletion procedures.

For information about how Meta itself collects and uses data made available through your connection, please review Meta’s Privacy Policy at https://www.facebook.com/policy.php and the Instagram Data Policy at https://www.instagram.com/legal/privacy. We are not responsible for Meta’s data practices.

2.8 Communications Information

We may collect information relating to communications sent to you or by you in connection with the Services, including emails, support requests, SMS communications where applicable, push notifications, in-app messages, and other operational or administrative communications.

Additional information about our SMS notification program, including the mobile information we collect, how we use it, and our practice of not sharing mobile information with third parties for marketing purposes, is described in Section 12 (Mobile Information and SMS Notifications) below.

2.9 Device, Usage, and Technical Information

When you access or use the Services, we may automatically collect certain technical and usage information, including IP address, browser type, browser settings, device identifiers, operating system, internet service provider, referring and exit pages, dates and times of access, clicks, session activity, error logs, diagnostic data, and similar information relating to your use of the Services.

2.10 Cookies and Similar Technologies

We may collect information through cookies, local storage, pixels, tags, SDKs, and similar technologies used to support session management, security, analytics, performance monitoring, preferences, and functionality of the Services.

2.11 Legal, Compliance, and Security Information

We may collect information necessary to protect the Services, enforce our Terms, comply with legal obligations, investigate suspected fraud or misuse, respond to legal requests, monitor platform integrity, or support claims, disputes, moderation, or enforcement activity.

3. Sources of Information

We may collect information directly from you, automatically from your device or browser, from other Users, from workspace administrators or team members, from third-party platforms you connect, from payment processors, from service providers acting on our behalf, and from other lawful sources consistent with this Privacy Policy.

4. How We Use Information

We may use the information we collect for the following purposes:

4.1 To Provide and Operate the Services

We use information to provide, maintain, support, and improve the Services, including Account creation, authentication, workspace functionality, Profile display, campaign management, proposal workflows, deliverable submission, communications, subscription administration, payment operations, claims management, and dispute resolution.

4.2 To Facilitate Campaigns, Proposals, and User Interactions

We use information to enable Users to create campaigns, send and receive proposals, finalize agreements, coordinate deliverables, communicate through the Services, administer campaign-related actions, and support claims or disputes between Users.

4.3 To Administer Workspaces and Multi-User Accounts

We use information to support workspace creation, role-based permissions, user invitations, administrative controls, workspace communications, subscription assignment, and related team-based functionality.

4.4 To Process Subscriptions, Billing, and Transactions

We use information to process subscription purchases, recurring billing, payment authorizations, transaction facilitation, payment status tracking, billing support, refunds or credits where applicable, and account access administration tied to subscription status.

4.5 To Communicate With You

We use information to send service-related communications, notices, security alerts, billing notices, campaign and proposal notifications, subscription updates, dispute communications, policy updates, support responses, and other messages relating to the Services.

We may also send marketing or promotional communications where permitted by law. You may opt out of non-essential promotional communications as described in the applicable communication.

4.6 To Improve and Develop the Services

We use information to analyze usage patterns, troubleshoot issues, improve functionality, develop new products and features, refine campaign and workspace workflows, evaluate performance, and support internal reporting and analytics.

4.7 To Protect the Services and Enforce Our Rights

We use information to detect, prevent, investigate, and address fraud, abuse, unauthorized access, security incidents, violations of our Terms, misuse of platform data, disputes, and other harmful or unlawful conduct.

4.8 To Comply With Legal Obligations

We use information to comply with applicable law, regulations, court orders, legal process, tax obligations, financial reporting requirements, and lawful requests from governmental or regulatory authorities.

4.9 To Create Aggregated or De-Identified Information

We may use information to create aggregated, de-identified, or anonymized data that no longer identifies an individual. We may use such information for lawful business purposes, including analytics, platform improvement, benchmarking, and internal reporting.

5. How We Disclose Information

We do not sell personal information for monetary consideration. We may disclose information as follows.

5.1 To Other Users

Because the Services are designed to facilitate collaboration among Users, we may disclose information to other Users as necessary to support platform functionality, including in connection with Profiles, workspaces, campaigns, proposals, agreements, deliverables, communications, disputes, and claims.

Such disclosures may include names, social media handles, business information, contact details, campaign information, proposal terms, deliverable content, and other information relevant to platform activity.

5.2 Within Workspaces and Organizations

If you participate in a workspace, organization, or multi-user account, your information may be accessible to authorized users within that workspace in accordance with applicable roles, permissions, and administrative controls.

Workspace administrators may have access to certain account, billing, usage, communication, or activity information relating to users within the workspace, as permitted by platform functionality.

5.3 To Service Providers and Contractors

We may disclose information to vendors, service providers, contractors, and agents that perform services on our behalf, including hosting, storage, analytics, payment processing, customer support, communications, security, infrastructure, monitoring, and software tools.

Such parties are authorized to access and use information only as reasonably necessary to perform services for us or comply with legal obligations.

A list of the principal categories of third-party subprocessors we engage to operate the Services is set forth in Section 16 (Subprocessors and Service Providers) below.

5.4 To Payment Processors

We may disclose payment-related information to third-party payment processors, such as Stripe, in order to process subscriptions, transactions, refunds, payment authorizations, and related billing workflows. Such processors handle information pursuant to their own terms and privacy policies.

5.5 To Third-Party Platforms and Integrations

If you connect a third-party account or authorize a third-party integration, we may disclose information to or receive information from that third party as necessary to support the requested integration or platform functionality.

5.6 For Legal, Regulatory, and Security Purposes

We may disclose information where we believe, in good faith, that such disclosure is necessary or appropriate to: (a) comply with applicable law, regulation, legal process, or governmental request; (b) enforce our Terms, policies, or agreements; (c) detect, investigate, or prevent fraud, abuse, security incidents, or technical issues; (d) protect the rights, property, or safety of the Company, Users, or others; or (e) support audits, compliance, litigation, or dispute resolution.

5.7 In Connection With a Business Transfer

We may disclose or transfer information in connection with an actual or proposed merger, acquisition, reorganization, financing, sale of assets, bankruptcy, dissolution, or other corporate transaction involving all or part of our business.

5.8 With Your Direction or Consent

We may disclose information where you direct us to do so or otherwise consent to the disclosure.

6. Cookies and Similar Technologies

We may use cookies and similar technologies to operate the Services, maintain sessions, store preferences, authenticate users, improve performance, analyze usage, support security measures, and develop insights regarding the use of the Services.

You may be able to control cookies through your browser settings or other device controls. However, disabling cookies or similar technologies may affect the availability or functionality of certain portions of the Services.

Where required by applicable law, we will request your consent to use non-essential cookies through a cookie banner or preference center before such cookies are placed on your device. You may withdraw or change your cookie preferences at any time through the cookie preference controls made available on the Services. We also honor recognized browser-based opt-out signals, such as the Global Privacy Control (GPC), to the extent required by applicable law.

7. Third-Party Services and Links

The Services may contain links to or integrate with third-party websites, services, advertisers, social media platforms, payment processors, or other resources not controlled by the Company. We are not responsible for the privacy practices of such third parties, and this Privacy Policy does not apply to information collected by them except to the extent expressly stated herein.

We encourage you to review the privacy policies of third-party services before providing information to them or authorizing integrations.

8. Data Retention

We retain information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to provide the Services, maintain records, support campaigns and proposals, administer workspaces, process subscriptions and transactions, resolve claims and disputes, enforce our Terms, comply with legal obligations, detect or prevent misuse, and protect the Services and our users.

Retention periods may vary depending on the nature of the information, the context in which it was collected, the existence of an active Account or workspace, applicable legal requirements, and legitimate business needs.

Even if you request deletion of your information, we may retain certain information where required or permitted by law, including for tax, accounting, fraud prevention, dispute resolution, enforcement, legal defense, or recordkeeping purposes.

Without limiting the foregoing, we generally retain SMS opt-in and opt-out records for at least four (4) years following the relevant event in order to comply with telecommunications and consumer-protection laws; payment and transaction records for at least seven (7) years for tax and financial-reporting purposes; and Account, workspace, and campaign records for the duration of the Account or workspace and for a reasonable period thereafter to support disputes, audits, and legal defense. We periodically review retention periods and reduce them where doing so is consistent with applicable law and our legitimate business needs.

9. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, use, alteration, or destruction.

Notwithstanding the foregoing, no method of transmission over the Internet, mobile network, or electronic storage system is completely secure. Accordingly, we cannot guarantee absolute security, and you provide information to us at your own risk.

You are responsible for maintaining the confidentiality and security of your Account credentials and for using the Services through reasonably secure means.

10. International Processing and Transfers

The Services are operated in the United States and may be supported by service providers and infrastructure located in the United States or other jurisdictions. As a result, your information may be collected, stored, transferred, or processed in jurisdictions whose privacy laws may differ from those of your place of residence.

By accessing or using the Services, you acknowledge that your information may be transferred to and processed in such jurisdictions, subject to applicable legal safeguards where required by law.

Where personal information of individuals in the European Economic Area, the United Kingdom, or Switzerland is transferred to a jurisdiction that has not been deemed to provide an adequate level of data protection by the relevant authority, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses (and, where applicable, the UK International Data Transfer Addendum) to provide a lawful basis for the transfer. Additional information about your rights with respect to such transfers is set forth in Section 14 (European Privacy Rights) below.

11. Your Rights and Choices

Depending on your jurisdiction and applicable law, you may have certain rights regarding your personal information, including the right to request access to, correction of, deletion of, or information about our processing of your personal information.

You may also have the right to opt out of certain promotional communications or exercise other rights under applicable privacy law.

We may take reasonable steps to verify your identity before responding to a request, and we may deny or limit a request where permitted by law.

11.1 Access, Correction, and Deletion Requests

To request access to, correction of, or deletion of your personal information, you may contact us using the contact information set forth below. Your request should include sufficient information for us to verify your identity and understand the nature of the request.

Where appropriate, you may also update certain Account or Profile information directly through the Services.

11.2 Marketing Communications

You may opt out of receiving promotional emails from us by using the unsubscribe link contained in such communications. Even if you opt out of promotional communications, we may still send you transactional, operational, legal, billing, support, security, and other service-related communications.

If you have opted in to receive SMS notifications, you may opt out at any time by replying STOP to any SMS message we send, or by updating your communication preferences in your Account Settings. See Section 12 (Mobile Information and SMS Notifications) for more information.

12. Mobile Information and SMS Notifications

This Section describes how we collect, use, store, and disclose mobile information in connection with our SMS notification program (the “SMS Program”). This Section supplements, and should be read together with, the other provisions of this Privacy Policy.

12.1 What We Collect

When you choose to opt in to the SMS Program, we collect (a) the mobile phone number you provide; (b) the date, time, and disclosure text shown to you at the moment you provided consent; (c) records of SMS messages we send to you, including delivery status, error codes, and timestamps; and (d) records of any opt-out requests, including the keyword used (such as STOP) and the time of the request.

12.2 How Consent Is Captured

Consent to receive SMS from the SMS Program is captured at account signup through a separate, unchecked SMS consent checkbox on the My Influency signup form. The checkbox is optional and is not a condition of creating an Account or using the Services. Only users who actively check the box are enrolled in the SMS Program. The disclosure text shown at the checkbox identifies My Influency as the sender, describes the categories of messages you will receive, discloses message frequency and that message and data rates may apply, and explains how to opt out.

12.3 How We Use Mobile Information

We use mobile information solely to (a) deliver the transactional SMS notifications you have consented to receive, such as visit reminders, post-deliverable reminders, and contract lifecycle updates; (b) honor opt-out and HELP requests; (c) maintain records of consent and opt-out status for compliance purposes; and (d) protect against fraud, abuse, or unauthorized use of the SMS Program.

12.4 No Sharing of Mobile Information for Marketing

We do not share, sell, rent, or transfer mobile information collected through the SMS Program with any third parties or affiliates for marketing or promotional purposes. Mobile opt-in data and consent records are excluded from any data-sharing arrangements with third parties for marketing purposes and will not be shared under any circumstances for such purposes. The only third parties with whom we share mobile information are the subprocessors strictly necessary to deliver the SMS messages you have consented to receive, including our SMS delivery vendor (Twilio, Inc.), and only to the extent required for message delivery, opt-out processing, and regulatory compliance. These subprocessors are contractually prohibited from using mobile information for marketing purposes.

12.5 How to Opt Out

You may opt out of the SMS Program at any time by (a) replying STOP to any SMS message we send, or (b) updating your communication preferences in your Account Settings. Opt-out requests are honored immediately. After opting out, you will not receive further SMS from the SMS Program; you will continue to receive in-app and email notifications consistent with your other communication preferences. You may re-enroll at any time by opting in again on the My Influency signup or settings page.

12.6 Retention

We retain SMS consent records, the disclosure text shown at the time of opt-in, message delivery logs, and opt-out records for the duration of your Account and for a reasonable period thereafter to comply with applicable law, including telecommunications and consumer-protection requirements. Records relating to consent and opt-out events are generally retained for at least four (4) years following the date of the event.

12.7 Children

The SMS Program is not directed to individuals under eighteen (18) years of age, and we do not knowingly enroll any individual under eighteen (18) in the SMS Program.

13. California Privacy Rights

If you are a California resident, you may have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), subject to applicable limitations and exceptions. Such rights may include the right to request access to personal information, correction of inaccurate personal information, deletion of certain personal information, and information about categories of information collected, used, disclosed, or retained.

California residents also have the right to limit the use and disclosure of sensitive personal information, to opt out of the sale or sharing of personal information (we do not sell or share, as described in Section 5.9), and to be free from unlawful discrimination for exercising these rights. You may exercise applicable rights by contacting us using the contact information below, or, where we make such mechanisms available, through the request submission tools provided on the Services. An authorized agent may submit a request on your behalf upon providing documentation satisfactory to us demonstrating that they have been authorized to act on your behalf.

We do not sell personal information for monetary consideration.

California residents may exercise applicable rights by contacting us using the contact information below.

14. European Privacy Rights (EU/UK/Switzerland)

This Section applies to individuals located in the European Economic Area, the United Kingdom, or Switzerland (“European Users”). For purposes of the EU General Data Protection Regulation (GDPR) and the UK GDPR, Influency, Inc. is the controller of personal information processed in connection with the Services.

14.1 Legal Bases for Processing

We process personal information of European Users on the following legal bases: (a) performance of a contract — to provide, operate, and support the Services and to perform our obligations under our Terms; (b) legitimate interests — including operating and improving the Services, securing the Services and our users, preventing fraud and abuse, conducting analytics and product research, and managing our business operations, in each case where such interests are not overridden by your rights and freedoms; (c) compliance with legal obligations — including tax, financial-reporting, telecommunications, and consumer-protection laws; and (d) consent — where required by law, such as for non-essential cookies, SMS opt-in, and certain marketing communications. Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

14.2 Your Rights as a Data Subject

Subject to applicable law and any limitations or exemptions provided therein, European Users have the rights to (a) access personal information we process about you; (b) request rectification of inaccurate or incomplete personal information; (c) request erasure of personal information; (d) request restriction of processing; (e) object to processing carried out on the basis of legitimate interests or for direct marketing purposes; (f) request data portability of information you have provided to us; and (g) where processing is based on consent, withdraw that consent at any time. You may exercise these rights by contacting us using the contact information in Section 20 (Contacting Us). We may request information necessary to confirm your identity before fulfilling a request.

14.3 International Transfers

Personal information of European Users is processed in the United States and other jurisdictions that may not have been deemed to provide an adequate level of data protection by the European Commission, the UK Information Commissioner, or the Swiss Federal Data Protection and Information Commissioner. Where we transfer personal information to such jurisdictions, we rely on appropriate safeguards, including the European Commission’s Standard Contractual Clauses and, for transfers from the United Kingdom, the UK International Data Transfer Addendum issued by the Information Commissioner’s Office. You may request a copy of these safeguards by contacting us using the contact information in Section 20.

14.4 Right to Lodge a Complaint

European Users have the right to lodge a complaint with a supervisory authority in the EU member state, UK, or Swiss canton of their habitual residence, place of work, or place of the alleged infringement if they consider that our processing of personal information violates applicable law. We would, however, appreciate the opportunity to address your concerns before you contact a supervisory authority, and encourage you to contact us first using the contact information in Section 20.

14.5 EU and UK Representative

Where required by Article 27 of the GDPR or Article 27 of the UK GDPR, we will designate a representative in the European Union and the United Kingdom and identify that representative on the Services. If you are a European User and require representative contact information, please contact us using the contact information in Section 20.

15. Other US State Privacy Rights

If you are a resident of a U.S. state that has enacted a comprehensive consumer privacy law, you may have certain rights regarding your personal information. The states currently covered by this Section include, without limitation, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Tennessee, Florida, Iowa, Indiana, New Jersey, Delaware, New Hampshire, Kentucky, Maryland, Minnesota, Nebraska, New Hampshire, and Rhode Island, in each case subject to the scope, exemptions, thresholds, and limitations of the applicable state’s law.

15.1 Rights You May Have

Subject to applicable law and verification requirements, eligible residents may have the right to (a) confirm whether we process personal information about you and access that information; (b) request correction of inaccurate personal information; (c) request deletion of personal information; (d) obtain a portable copy of personal information you provided to us; (e) opt out of the sale of personal information, targeted advertising based on personal information collected across non-affiliated websites or applications, and profiling that produces legal or similarly significant effects; and (f) limit our use and disclosure of sensitive personal information. We do not sell personal information, engage in targeted advertising of the kind described above, or engage in profiling that produces legal or similarly significant effects.

15.2 How to Exercise Your Rights

You may exercise applicable state-law rights by contacting us using the contact information in Section 20 (Contacting Us). We may take reasonable steps to verify your identity before responding, and we may deny or limit a request where permitted by law. If we deny your request, you may have the right to appeal that decision by contacting us at the same address with the subject line “Privacy Rights Appeal.”

16. Subprocessors and Service Providers

We engage third-party service providers (“subprocessors”) to operate the Services. These subprocessors process personal information on our behalf and are contractually obligated to use the information only to provide services to us, to maintain appropriate security and confidentiality safeguards, and not to use personal information for their own marketing purposes. The principal categories of subprocessors we use include the following:

Cloud infrastructure and hosting (e.g., Google Cloud Platform); database and authentication services (e.g., Google Firebase); SMS delivery and telecommunications (e.g., Twilio, Inc.); email delivery (e.g., transactional email service providers); payment processing and influencer payouts (e.g., Stripe, Inc., including Stripe Connect Express for influencer payouts); analytics and error monitoring (e.g., usage and crash-reporting providers); and customer support and ticketing tools.

We may update the list of subprocessors from time to time as our operations evolve. A current list of subprocessors is available upon request by contacting us at the address in Section 20 (Contacting Us). Where required by applicable law or contract (including in business-to-business agreements with Brands or Agencies), we will provide advance notice of material changes to our subprocessor list.

17. Data Breach Notification

We maintain an incident response program designed to detect, investigate, contain, and remediate security incidents that affect personal information. In the event of a personal data breach that is reasonably likely to result in a risk to the rights and freedoms of affected individuals, we will notify affected individuals and, where required, applicable supervisory authorities without undue delay, in accordance with applicable law (including, where applicable, within 72 hours of becoming aware of the breach under the EU and UK GDPR and within the timeframes required by U.S. state breach-notification statutes). Notifications will describe, to the extent known, the nature of the breach, the categories of personal information involved, the likely consequences, and the measures we have taken or propose to take in response.

18. Children’s Privacy

The Services are not directed to individuals under eighteen (18) years of age, and we do not knowingly collect personal information from individuals under eighteen (18). If we learn that we have collected personal information from an individual under eighteen (18) in a manner not permitted by law, we will take reasonable steps to delete such information.

19. Changes to This Privacy Policy

We may modify this Privacy Policy from time to time. When we do so, we will update the “Last Updated” date above and post the revised Privacy Policy through the Services.

Any changes will become effective upon posting unless otherwise stated. Your continued access to or use of the Services after the effective date of a revised Privacy Policy constitutes your acknowledgment of the updated Privacy Policy, to the extent permitted by law.

20. Contacting Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us using one of the methods below:

Email: kyle.painting@myinfluency.com

Mailing Address:

Influency, Inc.

3699 Lenox Rd NE, Apt. 508

Atlanta, GA 30305

United States

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