Privacy Policy

At GLOBALINK ("we", "us", "our"), we value data transparency. This Privacy Policy outlines how we collect, process, and protect data from:

• Registered Users & Subscribers: Commercial clients, DTC brands, and agencies utilizing our search, CRM, and outreach tools; and
• Digital Creators: Public digital content creators whose professional channels and business contacts are indexed in our B2B directory.

1. Data Controller

GLOBALINK Creator Intelligence operates as the data controller for user accounts and creator directory indexes. For any questions regarding privacy practices or rights under GDPR, UK GDPR, or CCPA, you may reach our Data Protection Officer at [email protected].

2. User & Customer Data (Subscribers)

When you register, subscribe, or interact with our platform, we collect the following categories of information:

• Account Information: When you sign in (via Google OAuth or email authentication), we collect your name, email address, profile avatar, and account tier settings.
• Payment & Billing Information: Billing transactions are handled exclusively by Creem.io, our designated Merchant of Record (PCI-DSS Level 1 compliant). We receive only confirmation tokens, transaction IDs, subscription states, and invoice references. We never see, transmit, or store your raw credit or debit card numbers on our infrastructure.
• Usage & CRM Activity: Search filters, saved creator lists, unlocked profiles, and outreach email dispatch logs are stored securely to provide your account history and Collab CRM pipeline.

3. Creator Data Indexed in Directory (B2B Legitimate Interest)

3.1 Scope of Creator Data

We index publicly available professional information, including:

• Creator social media handles, channel URLs, and public display names;
• Publicly published business inquiry email addresses and talent agency contact endpoints;
• Aggregated public performance statistics (subscriber and follower counts, median views, engagement rates, primary content categories, and geographical audience estimates).

3.2 Legal Basis under GDPR & Legitimate Interest Assessment

Under GDPR Article 6(1)(f), processing publicly disclosed professional contact information of digital creators for commercial directory indexing and brand partnership discovery constitutes a legitimate commercial interest. We have conducted a formal Legitimate Interest Assessment (LIA):

• Purpose Test: GLOBALINK facilitates economic opportunities by connecting bona fide consumer brands, DTC merchants, and agencies with content creators seeking commercial sponsorships and affiliate collaborations.
• Necessity Test: Indexing is strictly limited to verified, publicly published professional contact endpoints (such as YouTube business inquiry emails, Instagram business contacts, and official media kit links). We do not collect private personal data.
• Balancing Test: Content creators publicly distribute business contact channels specifically to attract commercial collaboration inquiries. The processing does not override creators' fundamental privacy rights because it aligns directly with their intended professional purpose and is safeguarded by an unconditional 48-hour opt-out mechanism.

3.3 Compatibility of Purpose (GDPR Article 6(4))

Pursuant to GDPR Article 6(4), our processing passes the compatibility test: creators publish their contact details with the reasonable expectation and affirmative intent to receive genuine commercial proposals from reputable brands. GLOBALINK does not repurpose creator information for unrelated advertising, mass automated scraping resale, or consumer credit profiling.

3.4 Data Controller vs. Data Processor Roles

To ensure complete legal transparency:

• Directory Compilation & Indexing: GLOBALINK acts as an independent Data Controller regarding the aggregation, indexing, and publication of publicly available creator profiles within our intelligence database.
• Email Outreach & Campaign Dispatch: When a registered client (brand or agency) initiates or sends collaboration proposals to creators via our outreach tools, the Client acts as the Data Controller determining the recipients, content, and frequency of the communication. GLOBALINK acts exclusively as a technical Data Processor providing dispatch infrastructure, subject to our Data Processing Addendum (DPA).

3.5 What We Do NOT Collect

We strictly do NOT collect, harvest, or store sensitive personal data, personal home addresses, private mobile telephone numbers, government identification, or non-public personal financial records of creators.

4. Creator Right to Erasure / Opt-Out (创作者下架权利)

We fully respect creators' rights over their personal data. Any creator wishing to remove or update their profile from GLOBALINK may do so at any time without fees or justification.

5. Data Security & Storage

We employ industry-standard security safeguards. All communications are encrypted in transit via HTTPS/TLS 1.3. Stored database assets are protected by AES-256 encryption hosted across Cloudflare's secure edge infrastructure. Access to administrative systems is restricted by strict role-based access control (RBAC) and multi-factor authentication.

6. Your Rights under GDPR & CCPA

Both users and creators have specific rights regarding their personal data, including:

• The right to access and obtain a copy of your personal data;
• The right to rectify inaccurate or incomplete records;
• The right to request immediate erasure of your profile ("Right to be Forgotten");
• The right to restrict or object to the processing of your data;
• The right to data portability.

To exercise any of these rights, please email [email protected]. We respond to all verified requests within 30 calendar days (or within 48 business hours for creator profile opt-outs).

7. Third-Party Sub-processors

We work with trusted third-party service providers to deliver our services:

• Creem.io: Merchant of Record, payment gateway, and PCI-compliant transaction processing.
• Cloudflare: Global CDN, Edge Functions hosting, DDoS protection, and SSL termination.
• PostHog: Privacy-focused product analytics and session debugging (with sensitive text masked).
• Resend: High-deliverability transactional and cold outreach email delivery gateway.

8. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect operational, legal, or regulatory changes. Any modifications will be posted here with an updated "Last Updated" date.

Billing Support Information

When you contact us about a purchase, cancellation, or refund, we use the account email, order reference, transaction status, and information you provide to locate the relevant purchase, verify account ownership, investigate the issue, and communicate the outcome. Relevant order and transaction details may be shared with our payment service to resolve the request. Please do not include passwords, full card numbers, or card security codes in a support message.

For purchase and support instructions, see the Terms of Service. For questions about billing support data, contact [email protected]; for privacy requests, contact [email protected].

9. Contact Us

If you have questions or concerns about this policy, contact us at:

• General Privacy Inquiries: [email protected]
• Customer Support: [email protected]