True Followers is a platform for all influencers who want to monetize their exclusive content. This Privacy Policy applies to Followrs, Influencers and all users of our platform and is part of our Terms of Use.

 

True Followrs is a Danish-based company with a global perspective. When you use our platform, you agree that your personal data that you provide directly to us or that we collect through your use of the platform may be transferred to and stored in Sweden and processed as described in this policy.

 

Information you provide through your account

This is information that you provide to us via text fields, such as your name, payment information and benefits. The information we collect varies depending on whether you create an account, become a Follower or become an Influencer.

 

First and last name

Email address

User name

Password

Country of residence

 

You can also sign up using a Facebook or Google account. We ask for permission to access basic information from your Facebook or Google account, such as your name, email and profile picture. You can choose to no longer share this information with us at any time by going to Facebook or Google to remove True Followr's access to that account and your ability to log in.

 

You also have the option to add additional information to your public profile, such as a location, social media links, and an about section, which we store along with any comments or messages you submit on True Followrs.

 

True Followr ("a Follower")

A True Followr is a person who joins True Followr's membership platform to follow and support an influencer's member content, ("a Followr"). As a Followr, you must provide your payment information to our payment intermediaries. You can see the privacy policy of these payment intermediaries on PayPal's and Checkout's websites. At this time, True Followers does not receive your full card number. Payment intermediaries provide us with a symbol representing your account, your card's expiry date, card type and the last four digits of your card number. If you are required to provide your name and email address to the payment intermediary, they will also provide us with this information.

 

We collect and process information about the Influencers you support, the level at which you support them, what benefits you receive and how often you support them.

Influencers

An Influencer is a person who creates and delivers content to his Followers via True Follower's membership platform, ("an Influencer"). To become a verified Influencer, you must create a page describing what you create and any benefits you offer, your age and upload a valid ID proof that verifies your identity. To receive payouts, you must create an account with our payment partners: PayPal or Checkout. We may also ask you for your bank account details in order to complete withdrawals. You must also provide us with additional information for tax purposes. Depending on where you live, you may need to fill out a form with a combination of:

 

First and last name

Address

CPR or employer identification number

Country of citizenship

Foreign tax registration number

Date of birth

Account information for withdrawals

Phone number

 

Additional information we collect

 

Automatically collected information

We collect information automatically when you navigate the website or through our third-party analytics providers. We may store usage information such as the type of device you use to access True Followrs, your operating system, browser type, IP address and device ID, the pages you visit or request, links you click, referring websites, user interactions and your keywords. We also derive your location from your self-reported country, your IP address and from your payment card.

 

Comments and messages

When you send messages or write comments, we can collect the things you share and record the activity on the website where users have replied, who they have communicated with, private messages, IP address and where the user was last logged in from.

 

User surveys

From time to time we may ask you to participate in user surveys. We may ask you for demographic information, including information about gender, ethnicity, race, age, sexual orientation, earnings and accessibility to better understand and serve our user base – you can choose to share this information or not. We collect such information to ensure that we provide fair and equal access to our services and to highlight Influencers to Followrs so they are easier to spot. We save your questionnaire answers to the extent that you participate.

 

Information about events

For in-person and online events, we may ask you for information. This is done to better adapt the event experience to the participants. This information may include name, email address, payment information, mobile phone number and QR code, demographic information, social media and other online accounts that you have, information about the types of works you create, and responses to surveys or feedback.

 

Blogs

We may collect and store your email address, your comments and your profile information from our blog pages to better understand your interests and improve our services to you.

 

Information collected by third parties

 

Cookies

On our website, we use cookies that collect information so that we and third parties can understand your use of True Followrs. See our cookie policy to learn more about our use of cookies on True Followrs.

 

Social Media Features and Widgets

We use social media features, including the Facebook Like button and widgets, such as the Share button or similar interactive widgets that run on True Followers. If you provide us with your information on social media, we may use it to interact with you on those social networks. These features may collect your IP address and other personal information, including which page you visit on our website, and may place a cookie to ensure that the feature works properly. Social Media features and widgets are either hosted by a third party or hosted directly on True Followers. Your interactions with those features are governed by the privacy policy of the company that provides them. If you want more information about the technologies used by these social networks, you can see their specific notices on the protection of personal data. Below you can find links to the most used social networks, so it's easy to find them:

 

Facebook: https://www.facebook.com/about/privacy/

Twitter: https://twitter.com/privacy

YouTube: https://policies.google.com/privacy

Instagram: https://help.instagram.com/155833707900388

 

How we use your information

 

We process your information to:

 

• confirm your identity to comply with Danish and international laws

• allow you to log into your account

• allow you to support an Influencer's membership program on True Followrs

• process member payments and payouts

• send you e-mails that are relevant to your use in relation to your e-mail preferences

• answer your questions

• provide you with existing and enhanced services related to your True Followers account

• advertise your True Followers account in order to increase its visibility

• highlight and celebrate Influencers

• market True Followr's products and services to you or to audiences similar to you, based on your networks and commonalities that others have with you, unless you opt-out in relation to your email preferences

• understand how you use the Service and create better tools for Influencers to service Followers

• conduct research and development to improve True Followers and develop future products

• prevent fraud and abuse on True Followers

 

Information we share with influencers

 

By becoming a Followr of an Influencer, you agree to have the following information shared with that Influencer:

 

• your name and email address and other profile information you have provided

• messages you send to Influencers via True Followers

• your physical address, city and country

• your phone number when you've signed up to support an Influencer who interacts with you via SMS or when you've signed up for event notifications via SMS

• all information about your contribution, including amount and start date, but not your full payment card details

• some aggregated and anonymized data about how you use True Followers that cannot be traced back to you or to an individual user

 

As an Influencer, you accept the terms of our data processing agreement (DPA) when you start our membership program. This DPA is called the Influencer DPA. The Influencer DPA is an influencer's promise to protect their Followers' personal data even after their membership on True Followrs. You can view a copy of the Influencer DPA here.

 

 

Information we share with third parties

 

We never sell your information to third parties. Except with Influencers, we only share data with third parties under the following circumstances:

 

• with your consent to Influencer's service providers so that they can deliver benefits. You should read the privacy policies of these service providers to see how they use and share your data.

• with our service providers, which are companies contractually engaged with us to provide services to us, such as order fulfillment, email management, data trend analysis, credit card processing, multi-currency settlement solutions, increasing our brand awareness and user engagement with marketing initiatives and fraud detection and prevention. These companies may have access to your data to perform their services and are contractually obligated to protect the data they receive from us to the same extent that True Followers protects it.

• to protect True Followr's security or integrity and to protect the rights, property or safety of True Followr, its employees, users or others if we believe disclosure is reasonably necessary to comply with a law, regulation or other valid legal process (eg subpoenas or arrest warrants served on True Followers). If we release your data, we will do our best to notify you immediately by email, unless the law prohibits us from doing so.

• in connection with a sale, merger, bankruptcy, sale of assets or reorganization of our business. We will notify you if another company receives your data. The promises in this privacy policy apply to all data transferred to a new company.

• With third-party apps used by Influencers to help run their membership programs.

• with partners in our partner register who may have access to your data to perform their services and who are contractually obligated to protect the data they receive from us to the same extent that True Followers protects it.

 

 

Information True Followrs collects from third-party apps

 

When you create a True Followrs account, you can choose to link one or more social accounts (e.g. Facebook or Google) to True Followrs, as we will thus collect and store some social information from these platforms, for example:

 

• number of followers

• number of postings

• number of views, likes and comments

 

This social information allows us to provide you with a better experience on True Followrs and creates space to develop True Followrs. We use this data to:

 

• help Influencers and Followers find each other on True Followers

• assess how we can give influencers greater success on True Followers

• analyze and develop our business

 

 

Information we share with the public

 

The following information is publicly available:

 

• your profile and your social media links and location if you add this information

• by default, the Influencers you support are displayed publicly.

• any posts, likes or comments you make

• Your aggregated or anonymized usage data in posts, press releases or in other ways to share information about the use of True Followers. Aggregated or anonymized data cannot be traced back to an individual True Followrs user

• monthly contribution value and goals that Influencers choose to publish

• number of Followers

 

Your preferences and rights over data

 

Choosing your preferences

Under Settings you can see your account preferences. You can view and adjust your settings by viewing your preferences and, if you want, by changing your choices.

 

Marketing activities

By accepting our Terms of Use, you expressly agree that True Followrs may:

 

• provide you with information about your service, service improvements or new True Followers products while you are on our website or using our apps.

• send you notices regarding your existing service or improvements related to your existing service when you are not on our platform, via email or text message if you have signed up for a service or event notification that uses text messages.

• send you messages related to services we provide that are separate from your existing service via email that you can opt out of.

• market True Followers to you and audiences similar to you based on your networks and commonalities others have with you, unless you opt out.

• send you marketing-related emails or text messages if you do not have a True Followers account but have consented to receive such messages, which you can opt-out of.

• ask for demographic information to highlight and celebrate Influencers.

• advertise your True Followers account in order to increase its visibility.

• send physical items to you by post as part of a promotional activity.

 

Opting out of marketing

You can object to the use of your data for marketing purposes at any time - and completely free of charge - when we collect your personal data and in all marketing communications. You can also object to the use of your data for marketing when you create your account, or at any time thereafter, by emailing support@truefollowrs.com.

 

By opting out, marketing-related e-mails are stopped. It may take up to 30 days before your opt-out request is processed. If you have an account with True Followrs, you will continue to receive service-related emails and text messages if you have signed up to receive text messages. You will also continue to receive service-related benefit shipments to the designated delivery address.

 

We never sell your information to third parties for marketing purposes without your prior consent.

 

Access, update or export information in your account

You may access and update certain information associated with your account by contacting support@truefollowrs.com.

 

How to turn off email notifications

You can change your email notifications under your email settings in your account. Although you can stop many email notifications this way, we will still send some important service emails.

Protection of personal data

True Followrs is an international company that complies with the General Data Protection Regulation (GDPR). We act as data controllers, as defined in the GDPR, and process personal data based on our legitimate interests and contractual necessity in order to offer you the service as described below. We also process and share personal data based on notification and users' consent, which our users can revoke at any time.

 

Personal information, purpose and legal basis, etc.

When you visit our website or apps, we use cookies and similar tracking technologies to collect data about your visits, including e.g. your navigation on the platform or in the app, the type of browser or device you use and your IP address. This data may contain personal data.

For the platform, we collect the data to ensure a stable, secure and user-friendly experience on our platform, as well as to keep statistics on our platform visitors. In some cases, data is processed to target marketing based on web browser behavior.

For apps, we collect the data to target marketing based on user behavior.

 

The legal basis for our processing is:

• for necessary (technical) cookies on the platform: Article 6(1)(f) of the GDPR, as we pursue our legitimate interest in ensuring functionality and security on our website, and

• for other cookies and similar technologies on the platform and in apps: Article 6(1)(a) of the GDPR, since you have given your consent to, for example, targeted marketing.

 

We disclose information about your use of the Platform and Apps to any third-party service providers that you have permitted to place cookies and/or similar tracking technologies when you use the Platform or Apps. If you have given your consent, such third parties include:

 

• Facebook

• Google

 

Personal data contained in cookies will be deleted in accordance with the lifetime/period of each specific cookie. Read more about our cookies, including their lifetime and the specific third-party providers (ie the recipients), in our Cookie Policy. You can read more about the processing of your personal data in the third-party provider's own privacy policies.

 

When you create an account and use the True Followers platform

True Followrs provides the ability for Influencers to offer exclusive content on our platform, and your Followers can then pay you a fixed monthly income to view your exclusive content (read more in “Terms of Use - True Followrs”).

When you create an account to access True Followrs, you will be asked to enter your name and contact information, email address, and a password of your choosing. We collect such information from you in order to provide you with access to the Platform and to ensure that your access account is secured with your own individual password. In addition, we will have access to information about your geographical location, gender and age. We collect information about your gender and age in order to tailor your experience of True Followrs to the best possible experience.

If you choose to link your True Followrs profile to Facebook, Google or a similar third-party service that manages personal data, True Followrs may collect and process information that you authorize the relevant third party to share with True Followrs. You can read more about the third-party providers' processing of your personal data in the third-party providers' own privacy policies.

With respect to Followers with a paid subscription to our platform, we will also collect payment information to provide you with access to your subscription. However, since True Followrs works with third-party payment service providers that operate independently in systems separate from True Followrs, no complete payment data, such as complete credit card numbers, will be stored by True Followrs.

 

Additionally, where the option is available, you may choose to provide us with additional information about your areas of interest. We collect such additional information from you to provide you with suggestions for content that may be of interest to you based on the information provided. However, such information is not required and completely optional.

 

We also collect information about the platform from which you download our app and about the source of your subscription, for example through our own channels, app stores, and in case you sign up to our platform as part of a promotion, or partnership with a third-party brand, product or service, we process this information to enable us to ensure that you receive the benefits of the subscription you have signed up for, to manage our relationships with partners and to measure campaign success.

 

In addition, we will have access to information about how you interact with our platform, including what content you have searched for, interacted with, viewed and saved in your profile. This includes the processing of technical data (such as unique platform ID, device IP address). We collect such information from you to improve your use of our Platform, including to make suggestions for related content, to analyze engagement with our Platform, and to ensure that we are able to properly reward Influencers for consumption of their content.

We process personal data: i) to provide our platform, including personal data that you choose to provide us in order to use our platform; and ii) to establish the source of your app download/subscription, is based on Article 6(1)(b) of the GDPR, as the information is necessary for the performance of a relationship with you.

 

Personal data processed to analyze your use of our platform and measure the success of campaigns is based on Article 6(1)(f) of the GDPR as we pursue our legitimate interests in operating and developing our platform.

 

We only keep your data as long as it is relevant to us and we have a legitimate purpose for keeping it. Your data will therefore be deleted in accordance with applicable data protection legislation and, as a general rule, your data will be deleted 5 years after the end of the financial year in which you choose to deregister from our platform.

In specific situations, we may extend our general retention periods (in the event of, for example, complaints, objections or other specific situations).

 

We pass on personal data included in our account registration to the relevant public authorities, including the tax and customs authorities, in connection with our statutory bookkeeping etc.

In addition, we pass on your personal data to the service providers of the online payment company that we use. Finally, we make your personal data available to our group companies and data processors, such as host, developers and responsible for our IT systems and to provide analytics services connected to our platform.

 

When you register as an Influencer

When you join True Followrs, we record your personal data on the platform and in our IT systems, including name, contact details, country of residence, log-on details and password and bank account details. In addition, we process information about income etc. (where applicable) and information related to your content such as ratings etc. We process this personal data as part of our business, including for the purpose of managing the influencer relationship, for billing purposes, to provide the services based on our contractual obligations with the influencers and to make their content available to users.

 

The legal basis for our processing is Article 6(1)(b) of the GDPR, as the processing is necessary for the performance of our influencer agreement, and Article 6(1)(f) of the GDPR, as we pursue our legitimate interest in the Influencer's administrative tasks and communications with the Influencers, as well as taking care of accounting and financial tasks.

Personal data will generally be deleted 5 years after the end of the financial year in which the influencer relationship has ended.

In specific situations, we may extend our general retention periods (in the event of, for example, complaints, objections or other specific situations).

We pass on personal data included in our account registration to the relevant public authorities, including the tax and customs authorities, in connection with our statutory bookkeeping etc.

 

We may pass on your personal data to our relevant business partners, including external advisers. Furthermore, we make your personal data available to our group companies and data processors, such as host, developers, etc.

 

Communication with us

When you communicate with us (e.g. via e-mail or via our contact form on our website), your communication will contain personal data, e.g. your contact information (including name and email address) and other personal data you may provide to us.

We process this personal data for the purpose of handling and answering your inquiries. The legal basis for the processing is Article 6(1)(f) of the GDPR, as we pursue our legitimate interests in handling general inquiries.

We only keep your data as long as it is relevant to us and we have a legitimate purpose for keeping it. Your data will therefore be deleted in accordance with applicable data protection legislation. Personal information relating to our general communication with you (such as e-mail enquiries) is deleted 5 years after the end of the financial year in which your last inquiry has been dealt with/ended.

In specific situations, we may extend our general storage periods (in the event of, for example, complaints, objections or other specific situations).

In addition, we pass on your personal data to the service providers of the online payment company that we use. Finally, we make your personal data available to our group companies and our data processors, such as host, developer and responsible for our IT and CRM systems.

 

When you are subject to direct marketing

When you subscribe to our newsletter or other marketing communications, we record your name, email address and any additional information you may have provided. We do this to better target our marketing to you. In addition, we process this personal data with the aim of being able to send you targeted communications.

The legal basis for our processing is the consent you have given in accordance with Section 10 of the Marketing Act.

We emphasize that you have the right to object at any time to our processing of your personal data regarding marketing, including direct marketing. In addition, you have the right to withdraw your consent at any time.

 

Personal information relating to our distribution of marketing communications is deleted 2 years after our last marketing communication has been distributed, unless you have withdrawn your consent before this time.

 

We make your personal data available to our group companies and data processors, such as host, developers and those responsible for our IT systems.

 

If you participate in competitions administered by us

If you decide to enter competitions administered by us, for example as part of direct marketing, we may ask you to provide personal data such as your name, email address and other contact details (if you have not already provided this to us) . We may also collect other personal information required to provide you with any prize offered in the event that you win the competition.

 

We process this personal data for the purpose of administering the competition, including contacting winners. The legal basis for the processing is Article 6(1)(f) of the GDPR, as we pursue our legitimate interests in pursuing and conducting promotional activities.

We only keep your data as long as it is relevant to us and we have a legitimate purpose for keeping it. Your data will therefore be deleted in accordance with applicable data protection legislation.

 

Personal information relating to competition administration is deleted 5 years after the end of the financial year in which the competition or draw has ended.

In specific situations, we may extend our general retention periods (in the event of, for example, complaints, objections or other specific situations).

 

We make your personal data available to our group companies and data processors, such as host, developers and those responsible for our IT and CRM systems that are used to administer the competition or that help to organize the competition.

 

If you visit our social media platforms (Facebook, Instagram, Twitter, Youtube, Tik Tok).

 

If you visit our account on platforms on e.g. Facebook, Instagram, Twitter, Youtube or TikTok, we can process the personal data that you have available to us via the specific settings, your reactions to content, including likes and comments, and any sharing of our content, etc.

We process this personal data for the purpose of managing our social media platforms and communicating with you through these platforms. The legal basis for the processing is Article 6(1)(f) of the GDPR, as we pursue the above-mentioned legitimate interests.

We only keep your data as long as it is relevant to us and we have a legitimate purpose for keeping it. Your data will therefore be deleted in accordance with applicable data protection legislation. Personal information relating to our social media platforms over which we have control is deleted 5 years after the end of the financial year in which such personal information was collected.

Please note that when you use our social media platforms, the provider (such as Facebook) will also process your personal data for their own purposes, including for targeted marketing purposes. You can find further information about these processing activities in the provider's own privacy policies.

 

 

Transfer of your personal data to third countries

We may transfer your personal data to countries outside the EU and the EEA if we make data available to any data processors in various third countries.

 

The basis for such a transfer is either:

 

• Commission decision of 4 June 2021 on standard contractual provisions for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council or;

• an EU Commission "Adequacy Decision" based on Article 45 of the GDPR.

 

Your rights, etc.

You have a number of special rights under the Data Protection Regulation to help you control your personal data, and we want to make it easy for you to exercise these rights:

 

• Right to withdraw consent

Where you have given your consent to our processing of your personal data, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us.

If you withdraw your consent, the withdrawal will not affect the lawfulness of processing that has already been carried out on the basis of your consent.

 

• Right to see information (right of access)

 

You have the right to be confirmed whether we collect or process your personal data and, if so, you have the right to request a copy of your personal data in digital format.

 

• Right to rectification

You have the right to demand that we correct any inaccurate personal data about you and that we fill in incomplete personal data.

 

• Right to erasure

In certain circumstances, you have the right to request that we delete personal data about you; for example if it is no longer necessary for the purposes for which it was originally collected.

 

• Right to restrict processing

In certain circumstances, you have the right to request that we restrict the processing of your personal data, e.g. if you believe that the personal data is not correct or lawfully processed.

 

• Right to object to the processing

In certain circumstances, you have the right to request that we stop processing your personal data.

 

• Right to data portability

In certain circumstances, you have the right to receive the personal data you have provided to us in a structured, commonly used, machine-readable format, and the right to have us transfer the data to another device where technically possible.

 

If you want to exercise your rights, please contact us.

 

You can read more about your rights in the Data Protection Authority's guidance on the rights of data subjects, which you can find at www.datatilsynet.dk.

 

 

 

Security

The security of your personal information is important to us and we follow industry standards to protect it.

 

Children

True Followrs is not intended for children under the age of 13, and children may not create an account or otherwise use True Followrs.

 

Changes

We may occasionally make changes to this policy. If we make material changes that adversely affect your rights under this policy, you will be notified before the changes become effective. If you continue to use True Followrs after a change to this policy, it means that you accept the new policy. If you have any questions, please email support@truefollowrs.com.

 

Complaint to the Danish Data Protection Authority

You have the right to lodge a complaint with the Danish Data Protection Authority if you are dissatisfied with the way we process your personal data. You will find the Data Protection Authority's contact information at www.datatilsynet.dk.

 

How to contact our data protection officer

If you have any concerns or questions about the Privacy Policy, you can contact us by email at support@truefollowrs.com.

 

Legal basis for processing your personal data

The legal basis for our processing of the information in this privacy policy follows from:

 

- The Data Protection Regulation, Article 6, subsection 1, point a-b

- The Data Protection Regulation, Article 7, subsection 1-4

- Data Protection Act, §11, subsection 2, point 2

 

Data storage period

We retain your account information for ten years after the account was last active, unless you delete or request us to delete your account. We may continue to retain certain information even after you delete your account if required by us to comply with various laws.