Commentfluencer
Legal

Privacy Policy

What we collect, how we use it, who we share it with, and the rights you have over your data.

Pre-launch draft. These documents are written in good faith but must be reviewed and approved by licensed counsel before any real-money launch. They are not legal advice.

Effective date: [to be set at launch]

This Privacy Policy explains how Commentfluencer, Inc. (“Commentfluencer,” “we,” “us,” “our”) collects, uses, shares, and protects information when you use commentfluencer.com and our related applications and services (the “Platform”). By using the Platform, you agree to this Policy. Capitalized terms not defined here have the meaning given in our Terms of Service.

1. Who this applies to

This Policy applies to Brands, Commenters, visitors to our site, and end users who click tracked links generated through the Platform. The Platform is intended for users 18 and older; we do not knowingly collect data from anyone under 18 (see Section 9).

2. Information we collect

2.1 Information you provide

  • Account and profile data: name, email, password (hashed), role (Brand/Commenter), business information (for Brands), profile details, niche/category tags, and rate preferences.
  • Social account data you submit: links/handles to your TikTok, Instagram, and YouTube accounts, verification information you provide to prove ownership, and links to specific comments you want counted toward your stats and leaderboard ranking.
  • Communications: messages you send through in-app messaging, and support requests and correspondence.
  • Tax and payout onboarding data: collected and verified by our payments provider (Stripe) — see Section 2.4.

2.2 Public social-media data we collect (scraping / APIs)

To power verification, profile stats, brand discovery, and the public leaderboard, we collect publicly available data about linked social accounts, such as public comments, public comment like counts, public profile metrics, post/video references, and timestamps. We obtain this via official platform APIs where available and via third-party data providers (e.g., Apify, Bright Data) and our own scraping of public pages where APIs do not expose the needed data (comments left on others’ content are largely not available through official APIs). We collect this only for linked accounts and re-check it periodically to keep stats current. We do not collect private messages or non-public account data.

2.3 Click, tracking, and device data

When a tracked link is used, and when you browse the Platform, we (and our tracking infrastructure) collect: IP address, user-agent and device/browser information, referrer, click identifiers, timestamps, approximate (IP-derived) location, the tracked link/Deal involved, and conversion/postback data reported by Brands. This is the billing source of truth for clicks and conversions and is used for attribution and fraud detection.

2.4 Payment data (via Stripe)

Payments and payouts are handled by Stripe. Brands provide card/payment details and Commenters complete KYC/identity verification and bank/payout details directly to Stripe; Stripe also collects tax-form information (W-9/W-8). We do not store full card numbers or full bank-account numbers. We receive limited information from Stripe (e.g., payment/payout status, masked identifiers, onboarding/verification status) to operate the Platform. Stripe’s handling of your data is governed by Stripe’s Privacy Policy and the Stripe Connected Account Agreement.

2.5 Cookies and similar technologies

We use cookies and similar technologies for authentication/sessions, security, preferences, analytics, and click attribution. See Section 6.

3. How we use information

We use information to:

  • Operate the marketplace: create and secure accounts, verify social accounts, power search/discovery, messaging, and deal flow;
  • Track and attribute clicks and conversions, calculate commissions, the 20% Platform Fee, and payouts, and maintain our authoritative billing records;
  • Facilitate payments and payouts through Stripe, including holds, thresholds, clawbacks, and tax reporting;
  • Detect and prevent fraud and abuse (invalid traffic, bots, fake engagement, self-dealing), enforce our Terms and Acceptable Use Policy, and ensure FTC-disclosure and platform-rule compliance;
  • Display public profile stats and the leaderboard based on verified public-comment data;
  • Communicate with you (transactional notices, support, and — where permitted — product updates);
  • Improve and secure the Platform and comply with legal obligations.

3.1 Legal bases (EEA/UK users)

Where the GDPR/UK GDPR applies, we rely on: performance of a contract (operating the Platform and processing Deals/payments), legitimate interests (security, fraud prevention, displaying public stats, improving the Platform), consent (certain cookies/marketing, where required), and compliance with legal obligations (tax, anti-fraud, record-keeping).

4. How we share information

We are not in the business of selling your personal information. We share information as follows:

  • Between Brands and Commenters: to enable Deals — e.g., a Commenter’s public profile, stats, and handles are visible to Brands; messaging is shared between the parties.
  • Service providers / processors, including:
    • Supabase — authentication, database, and hosting of application data;
    • Stripe — payments, payouts, KYC, and tax reporting;
    • Apify / Bright Data (and similar) — collection of public social data;
    • Social platform APIs (YouTube/Google, TikTok, Instagram/Meta) — where used for verification/stats;
    • hosting, analytics, email, logging, and fraud-prevention vendors.
  • Public leaderboard and profiles: verified public-comment stats and rankings are publicly displayed, which is core to the product.
  • Legal and safety: to comply with law, respond to lawful requests, enforce our Terms, and protect rights, safety, and the integrity of the Platform.
  • Business transfers: in a merger, acquisition, financing, or sale of assets, subject to this Policy.

We require service providers to protect your information and use it only to provide services to us.

5. International data transfers

We are US-based, and we and our providers may process information in the United States and other countries. Where we transfer personal data from the EEA/UK or other regions, we rely on appropriate safeguards (such as Standard Contractual Clauses) where required. By using the Platform, you understand your information may be processed in countries with different data-protection laws than your own.

6. Cookies and tracking technologies

We use:

  • Essential cookies — authentication, session, security, and fraud prevention (cannot be disabled without breaking the Platform);
  • Functional cookies — preferences;
  • Analytics — to understand usage and improve the Platform;
  • Attribution identifiers — click IDs and related identifiers passed through our tracked redirects to attribute clicks/conversions.

You can control cookies through your browser settings; disabling some cookies may impair functionality. Where required, we present a consent banner and honor applicable opt-out signals (e.g., Global Privacy Control).

7. Data retention

We retain personal data for as long as needed to provide the Platform and for legitimate business and legal purposes, including:

  • Account/profile data — while your account is active and for a reasonable period afterward;
  • Tracking, attribution, commission, and payout records — retained as long as needed for billing, reconciliation, dispute resolution, fraud prevention, and to meet financial and tax record-keeping obligations;
  • Public social-data/stats — refreshed periodically; historical snapshots may be retained for leaderboard and integrity purposes;
  • Payment/tax records — retained by Stripe and by us as required by law.

When data is no longer needed, we delete or de-identify it.

8. Your rights and choices

Depending on your location, you may have rights to access, correct, delete, port, or restrict your personal data, to object to certain processing, and to withdraw consent. California residents (CCPA/CPRA) have rights to know, delete, correct, and opt out of “sale”/“sharing” (we do not sell personal information) and to non-discrimination. To exercise rights, contact privacy@commentfluencer.com; we will verify your request and respond as required by law. You may also unsubscribe from marketing emails at any time. Some data must be retained for legal, security, fraud-prevention, and tax reasons even after a deletion request.

8.1 Social-data and scraping disclosure; deletion path

We collect public social-media data about linked accounts to operate verification, stats, and the leaderboard. If you are a Commenter, you can unlink an account and request that we stop collecting new data for it and remove your associated public stats from the Platform. If you believe we have displayed public data about you and you want it removed, email privacy@commentfluencer.com and we will review and honor valid requests consistent with applicable law and our legitimate-interest and record-keeping obligations. We also honor applicable platform and legal requirements for handling public data.

9. Children

The Platform is for users 18 and older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us information, contact privacy@commentfluencer.com and we will delete it.

10. Security

We use administrative, technical, and organizational safeguards (e.g., encryption in transit, access controls, hashed credentials, and reliance on Stripe for sensitive payment data) to protect information. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security. Protect your account credentials and notify us of any suspected compromise.

11. Third-party links and services

The Platform links to third-party sites (e.g., Brand destinations, social platforms, Stripe). Their privacy practices are governed by their own policies, not this one. Review them before providing information.

12. Changes to this Policy

We may update this Policy. If we make material changes, we will provide reasonable notice and update the “Effective date” above. Your continued use after changes take effect constitutes acceptance.

13. Contact

Commentfluencer, Inc.
Privacy: privacy@commentfluencer.com
General support: support@commentfluencer.com
Website: commentfluencer.com