Privacy Notice

1. About this Privacy Notice

This Privacy Notice explains how Ayara Modest Wear, trading as Modest Creator Hub (“we”, “us” or “our”), collects, uses, stores and shares personal information when you:

• visit modestcreatorhub.com;
• create or manage an account;
• use our creator marketplace;
• participate in campaigns or collaborations;
• purchase a subscription or make or receive a payment;
• contact us or request support;
• subscribe to marketing communications; or
• otherwise interact with our services.

We are the controller of the personal information described in this Privacy Notice unless we tell you otherwise.

Our details are:

• Legal name: Ayara Modest Wear
• Trading name: Modest Creator Hub
• Company number: 16538800
• Registered office: Unit 5, Maidenhead Enterprise Centre, Maidenhead, SL6 7BE, United Kingdom
• Contact email: privacy@modestcreatorhub.com
• Telephone: 020234224127

2. Who our platform is for

Our platform connects content creators with brands seeking user-generated content, social media content, photography and related creative services.

The platform is intended only for people aged 18 or over. We do not knowingly collect personal information from children.

3. Personal information we collect

The information we collect depends on how you use the platform.

3.1 Account and identity information

• name;
• display name;
• username;
• email address;
• telephone number;
• password and authentication information;
• profile photograph;
• date of birth or confirmation that you are at least 18;
• country, city and time zone;
• account type;
• account status; and
• identity or verification status.

We do not receive your account password in readable form.

3.2 Creator profile information

If you register as a creator, we may collect:

• biography and portfolio information;
• photographs, videos, audio and other creative content;
• social media usernames and profile links;
• follower numbers, average views and engagement information;
• languages;
• areas of content experience;
• content styles and service preferences;
• availability and turnaround times;
• prices, rates and preferred currency;
• campaign applications and proposals;
• reviews and ratings; and
• information you choose to make publicly available on your profile.

Creators should not upload private, confidential or unnecessary personal information in public profiles or portfolios.

3.3 Brand and business information

If you register on behalf of a brand, we may collect:

• company or trading name;
• company registration information;
• business address;
• website address;
• industry and company size;
• logo and brand assets;
• contact name and job title;
• billing contact information;
• campaign briefs;
• creator requirements; and
• information about products or services promoted through campaigns.

3.4 Campaign and collaboration information

• campaign applications and invitations;
• proposals and agreed fees;
• contracts and usage-rights information;
• messages between creators and brands;
• uploaded briefs and supporting materials;
• draft and final deliverables;
• revision requests;
• approvals;
• campaign dates and progress;
• complaints and disputes; and
• reviews and feedback.

3.5 Payment information

Payments may be processed by Stripe or another payment provider identified at checkout. We may collect or receive:

• billing name and address;
• payment status;
• transaction amounts;
• currency;
• subscription plan;
• payment-provider customer identifiers;
• connected-account identifiers;
• invoice information;
• refund information; and
• limited payment details such as card type and the final digits of a card.

We do not intend to store complete payment-card details or creators’ complete bank-account details. These are handled by our payment provider. Payment providers may carry out identity, anti-fraud, anti-money-laundering and account-verification checks under their own privacy notices.

3.6 Communications

We may collect information contained in:

• customer-service enquiries;
• emails and contact forms;
• marketplace messages;
• feedback and surveys;
• complaints;
• dispute communications; and
• calls or meetings, where applicable.

We will notify you if a call or meeting is recorded.

3.7 Technical and usage information

• IP address;
• browser type and version;
• device type;
• operating system;
• approximate location derived from an IP address;
• login dates and times;
• pages viewed;
• links selected;
• referring website;
• session information;
• error reports;
• security logs; and
• cookie and analytics identifiers.

Please see our Cookie Notice for more information about our use of cookies and similar technologies.

3.8 Marketing information

• marketing preferences;
• communication preferences;
• responses to campaigns;
• email opens and link selections, where permitted; and
• information about how you heard about us.

4. Information that may be more sensitive

Some profile information, photographs or content may reveal or suggest information about a person’s religion, ethnicity, health or other protected characteristics. We do not require a creator to state their religion to use the platform.

Where you voluntarily provide information that constitutes special-category personal data, we will process it only where:

• it is necessary for a lawful and clearly explained purpose;
• an additional condition under data-protection law applies; and
• where required, you have given explicit consent.

You may withdraw consent for this processing by contacting us, although this will not affect processing that took place before withdrawal. We recommend that brands use objective campaign requirements and do not request sensitive information unless it is genuinely necessary and legally permissible.

5. How we collect information

Directly from you

For example, when you register, complete a profile, upload content, post or apply for a campaign, make a payment, send a message or contact support.

From other platform users

For example, when a brand invites a creator to a campaign, a creator submits work, a user leaves a review or someone raises a complaint.

From third-party services

• authentication providers;
• payment providers;
• social media platforms;
• analytics providers;
• fraud-prevention providers;
• identity-verification providers; and
• publicly available sources.

Where you connect a third-party account, we receive only the information permitted by your settings and the third party’s authorisation process.

Automatically

We collect some technical and usage information automatically through cookies, logs and similar technologies.

6. How and why we use personal information

6.1 Creating and administering accounts

• register you;
• authenticate your identity;
• maintain your account;
• provide account features;
• send service messages; and
• manage account security.

Lawful basis: performance of a contract and our legitimate interests in operating a secure platform.

6.2 Providing the marketplace

• display creator profiles;
• enable creator search and filtering;
• allow brands to post campaigns;
• enable applications and invitations;
• facilitate communications;
• manage collaborations;
• deliver and approve content;
• provide reviews and ratings; and
• maintain a record of transactions.

Lawful basis: performance of a contract and our legitimate interests in providing and improving the marketplace.

6.3 Processing subscriptions, payments and payouts

• collect subscription fees;
• process marketplace payments;
• calculate platform fees;
• facilitate creator payouts;
• issue invoices;
• administer refunds;
• prevent duplicate or unauthorised payments; and
• maintain financial records.

Lawful basis: performance of a contract, compliance with legal obligations and our legitimate interests in administering payments and preventing fraud.

6.4 Verification, trust and safety

• verify accounts;
• prevent fraud and misuse;
• enforce our Terms and Conditions;
• investigate suspicious activity;
• moderate campaigns and portfolios;
• manage reports and disputes;
• protect users; and
• secure our systems.

Lawful basis: our legitimate interests, compliance with legal obligations and, where necessary, the establishment, exercise or defence of legal claims.

6.5 Customer service

• answer questions;
• resolve technical problems;
• respond to complaints;
• manage disputes; and
• provide account support.

Lawful basis: performance of a contract and our legitimate interests in supporting users.

6.6 Improving the platform

• understand how the service is used;
• improve navigation and features;
• test new functionality;
• diagnose errors;
• produce aggregated reports; and
• improve creator matching and campaign recommendations.

Lawful basis: our legitimate interests in improving and developing our services. Where we use automated recommendations, these are intended to support discovery and do not ordinarily make decisions that produce legal or similarly significant effects without human involvement.

6.7 Marketing

• new platform features;
• creator opportunities;
• brand services;
• events;
• guides and resources; and
• relevant offers.

We will obtain consent where required. You may unsubscribe at any time through the link in a marketing email or through your account settings. Lawful basis: consent or our legitimate interests where electronic-marketing law permits.

6.8 Legal and regulatory compliance

• comply with tax and accounting requirements;
• respond to lawful requests;
• assist regulators or law-enforcement authorities;
• establish or defend legal claims; and
• comply with court orders.

Lawful basis: compliance with legal obligations and our legitimate interests in protecting our legal rights.

7. Legitimate interests

Where we rely on legitimate interests, those interests may include:

• operating and improving the platform;
• enabling creators and brands to collaborate;
• protecting users and systems;
• preventing fraud;
• understanding platform performance;
• providing relevant business communications; and
• establishing or defending legal claims.

We consider whether our interests are proportionate and whether your rights override those interests. You may object to processing based on legitimate interests by contacting us at privacy@modestcreatorhub.com.

8. Public profiles and marketplace information

Approved creator profiles may be publicly visible and may appear in:

• platform search results;
• public creator pages;
• search-engine results;
• featured-creator pages; and
• platform promotional materials where permission has been obtained.

Information marked private will not be displayed publicly. Even after public information is removed, copies may remain temporarily in search-engine caches or third-party archives outside our immediate control.

Campaign briefs may be visible to eligible creators. Private campaign materials and deliverables are accessible only to authorised participants and administrators, subject to our technical controls.

9. Who we share information with

Other platform users

Information may be shared with creators or brands where necessary to facilitate campaigns and collaborations.

Service providers

• cloud hosting and databases;
• file and video storage;
• authentication;
• payment processing;
• email delivery;
• analytics;
• customer support;
• fraud prevention;
• identity verification;
• error monitoring; and
• professional services.

Service providers may use information only in accordance with their contractual responsibilities and applicable law.

Payment providers

We may share information with Stripe and relevant banking or payment partners to process subscriptions, payments, connected accounts, refunds and payouts.

Professional advisers

We may disclose information to lawyers, accountants, insurers, auditors or consultants where reasonably necessary.

Authorities and legal recipients

We may disclose information where required by law or where reasonably necessary to protect rights, safety, users or the public.

Business transfers

If our business is sold, reorganised, financed or merged, personal information may be disclosed to professional advisers and relevant parties, subject to appropriate safeguards.

We do not sell personal information.

10. International transfers

Some service providers may process personal information outside the United Kingdom. Where personal information is transferred internationally, we will use an appropriate safeguard where required, such as:

• UK adequacy regulations;
• the UK International Data Transfer Agreement;
• the UK Addendum to approved standard contractual clauses; or
• another lawful transfer mechanism.

You may contact us for further information about the safeguards used for international transfers.

11. How long we keep personal information

We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Notice. Our general retention approach is:

• account information: while the account is active and normally for up to six years afterwards where required for legal, contractual or dispute purposes;
• financial and transaction records: normally six years after the relevant financial period or transaction;
• campaign and collaboration records: normally six years after completion;
• unsuccessful or withdrawn applications: normally up to two years;
• support requests and complaints: normally up to three years after resolution, or longer where a legal dispute exists;
• marketing records: until consent is withdrawn or the information is no longer needed, with a limited suppression record retained to respect opt-outs;
• security logs: normally up to 24 months;
• cookie and analytics information: for the period stated in our Cookie Notice;
• identity-verification information: for the period required by the verification or payment provider and applicable law; and
• deleted public content: removed from active display promptly, although secure backups may retain it for a limited period.

We may retain information for longer where required by law, tax obligations, fraud prevention, dispute resolution or legal claims. We may anonymise information so it can no longer identify an individual. Anonymised information may be retained and used indefinitely.

12. Security

We use appropriate organisational and technical measures designed to protect personal information, which may include:

• encryption in transit;
• access controls;
• authentication;
• role-based permissions;
• secure cloud services;
• logging and monitoring;
• staff and contractor confidentiality obligations;
• secure payment processing; and
• regular review of access permissions.

No online system can be guaranteed completely secure. You are responsible for keeping login details confidential and for notifying us promptly of suspected unauthorised account use.

13. Your rights

Depending on the circumstances, you may have the right to:

• request access to your personal information;
• request correction of inaccurate or incomplete information;
• request deletion of personal information;
• request restriction of processing;
• object to processing based on legitimate interests;
• object to direct marketing at any time;
• request transfer of information you provided to us;
• withdraw consent where processing is based on consent; and
• request information about certain automated decisions.

These rights are not absolute and may be subject to legal exceptions. To exercise a right, contact privacy@modestcreatorhub.com. We may need to verify your identity before responding. We normally respond within one month, although the law allows additional time for complex or numerous requests.

Your right to object

You have the right to object at any time to the use of your personal information for direct marketing. You may also object to processing based on our legitimate interests. We will stop that processing unless we demonstrate compelling legitimate grounds or need the information for legal claims.

14. Closing an account

You may request account closure through your account settings or by contacting us. Closing an account may not immediately delete all information. We may retain transaction, payment, contractual, fraud-prevention, dispute and legal records where required or permitted. Public profile information will be removed or anonymised within a reasonable period, subject to technical and legal limitations.

15. Cookies

We use essential cookies required for the platform to function. With consent where required, we may also use analytics, preference and marketing cookies. Further details, including how to change your choices, are provided in our Cookie Notice and cookie-preference centre.

16. Third-party links and services

Our platform may contain links to social media platforms, brand websites or other third-party services. We are not responsible for the privacy practices of third parties. You should review their privacy information before providing personal information.

17. Changes to this notice

We may update this Privacy Notice to reflect changes to our services, suppliers or legal obligations. We will publish the updated version on the website and change the “Last updated” date. Where changes are material, we may also notify registered users by email or through the platform.

18. Complaints

Please contact us first at privacy@modestcreatorhub.com so that we can try to resolve your concern. You also have the right to complain to the Information Commissioner’s Office. Details about contacting the ICO are available on its official website. If you are outside the United Kingdom, you may also have the right to contact your local data-protection authority.

19. Contact us

Questions about this Privacy Notice or our use of personal information should be sent to:

• Ayara Modest Wear t/a Modest Creator Hub
• Unit 5, Maidenhead Enterprise Centre, Maidenhead, SL6 7BE
• Company number: 16538800
• Email: privacy@modestcreatorhub.com
• Telephone: 020234224127