INFLUSWAY FZCO

Domain: influsway.com Effective Date: 23 June 2026 Status: Publication-ready

Privacy Policy — International

Entity: INFLUSWAY FZCO Domain: influsway.com Effective Date: 23 June 2026 Version: 2026-06-V6-PRIVACY-COM

1. Introduction

1.1. INFLUSWAY FZCO (“Influsway”, “we”, “our”, or “us”) operates an international influencer marketing marketplace connecting Businesses and Influencers across multiple jurisdictions.

1.2. This Privacy Policy explains how we collect, use, process, disclose, store, and protect personal data when Users access or use the Platform.

1.3. This Policy is intended to comply with:

• UAE Federal Decree Law No. 45 of 2021 concerning the Protection of Personal Data (“UAE PDPL”)
• where applicable, the EU General Data Protection Regulation (“GDPR”)
• where applicable, the Digital Personal Data Protection Act, 2023 of India (“India DPDP Act”)
• other applicable privacy laws depending on the User’s location and Campaign jurisdiction

2. Data Controller

The data controller responsible for personal data processed through the Platform is:

INFLUSWAY FZCO IFZA Business Park, DDP PO Box 342001 Dubai, United Arab Emirates

Privacy contact: contact@influsway.com

3. Personal Data We Collect

3.1 Registration Data

We may collect:

• full name
• email address
• mobile number
• social media usernames
• account credentials
• business details
• billing details

3.2 Identity and Compliance Data

Where required for verification, payment, fraud prevention, legal, or regulatory purposes, we may collect:

• government identification documents
• trade licenses
• influencer permits or licensing records where applicable
• jurisdiction-specific compliance documentation
• payment verification records
• other documents reasonably required for compliance checks

3.3 Campaign Data

We may collect:

• Campaign briefs
• Deliverables
• approval records
• revision requests
• dispute materials
• communication history
• timestamps and audit logs

3.4 Wallet and Payment Data

Payments may be processed through Mamo Pay or another licensed payment service provider. We may retain:

• wallet balances
• payout records
• transaction references
• payment metadata
• refund records
• chargeback or dispute records

3.5 Technical and Usage Data

We may automatically collect:

• IP addresses
• browser and device information
• session logs
• usage analytics
• approximate geolocation
• crash logs
• security logs

3.6 Social Media API Data

Where Users connect social media accounts, we may access data through permissions approved under our Meta App Review or other applicable platform review processes, including:

• profile information
• engagement metrics
• follower counts
• media insights
• audience analytics
• performance data

We use such data only for authorized Platform purposes, including profile display, influencer scoring, analytics, quality assessment, and Campaign facilitation.

4. Legal Basis for Processing

We process personal data where necessary to:

• perform Platform contracts
• facilitate Campaigns
• process payments and payouts
• comply with applicable legal obligations
• prevent fraud and platform abuse
• enforce Platform rules
• administer disputes
• improve Platform functionality
• obtain consent where required by law

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

• platform security
• fraud prevention
• analytics
• quality score calculation
• marketplace integrity
• enforcement of legal rights
• user support

Users may withdraw consent where processing is based on consent, subject to legal, regulatory, and contractual limitations.

5. Automated Processing and Platform Scoring

5.1. The Platform may use automated or semi-automated systems to:

• calculate influencer quality scores
• rank profiles
• prioritize search visibility
• recommend Users or Campaigns
• detect suspicious activity
• support fraud prevention

5.2. Such systems may process engagement metrics, follower counts, response rates, Campaign completion history, dispute rates, revision history, verification status, and other performance indicators.

5.3. Automated processing may affect User visibility, discoverability, and marketplace opportunities on the Platform.

5.4. Users may contact us at the relevant privacy contact email to request more information about automated processing that materially affects them, subject to applicable law.

6. How We Use Personal Data

We may use personal data to:

• operate the Platform
• facilitate Campaigns
• process payments and payouts
• verify Users
• detect fraud and misuse
• enforce agreements
• calculate quality scores
• provide customer support
• comply with regulatory obligations
• improve Platform services
• send operational communications
• send marketing communications where permitted by law

Users may opt out of marketing communications through unsubscribe links, account preferences, or by contacting us.

7. Cookies and Tracking Technologies

7.1. The Platform may use cookies and similar technologies, including:

• essential cookies required for login, authentication, security, and Platform functionality
• analytics cookies used to understand Platform usage
• advertising and remarketing cookies used to measure Campaign performance and advertising effectiveness

7.2. Tools used may include:

• Google Analytics 4
• Meta Pixel
• similar analytics or advertising technologies

7.3. Where required by law, Users may accept or reject non-essential cookies through consent tools provided on the Platform.

7.4. Users may also manage cookies through browser settings.

8. International Data Transfers

8.1. Personal data may be processed across multiple jurisdictions in connection with:

• international Campaigns
• cloud infrastructure
• analytics services
• customer support
• payment processing
• social media API integrations
• email delivery services

8.2. Where required by applicable law, we use reasonable safeguards for international data transfers, which may include contractual protections, processor obligations, standard contractual clauses or equivalent safeguards, user consent, or other transfer mechanisms recognized under applicable privacy laws.

8.3. Users acknowledge that Platform operations may involve cross-border processing of personal data.

9. Data Sharing and Sub-Processors

9.1. We may share personal data with:

• Campaign counterparties
• Mamo Pay or another licensed payment service provider
• hosting or cloud infrastructure providers
• Google Analytics or similar analytics providers
• Meta Platforms and social media API providers
• Mandrill, Mailchimp, or equivalent email infrastructure providers
• fraud prevention and verification providers
• professional advisers
• legal, regulatory, or law enforcement authorities where required

9.2. We do not sell personal data.

9.3. Third-party providers may process personal data under their own contractual and legal obligations.

10. Data Retention

10.1. Financial and transactional records may be retained for up to seven (7) years or longer where required by law.

10.2. Account information may be retained while the account remains active and for a reasonable period after account closure for legal, audit, fraud prevention, and dispute purposes.

10.3. Campaign records, Deliverables, approval logs, dispute materials, and audit records may be retained for evidentiary, compliance, and fraud prevention purposes.

10.4. Technical logs may be retained for a limited period reasonably necessary for security, diagnostics, fraud prevention, and audit purposes.

10.5. Marketing data may be retained until the User opts out or the data is no longer required for the relevant purpose.

10.6. Verification, KYC, anti-fraud, compliance, audit, and dispute records may be retained for compliance, fraud prevention, audit, regulatory, or legal purposes for a period reasonably necessary to satisfy those purposes, including after account closure.

11. Data Security

11.1. We implement reasonable technical and organizational safeguards designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

11.2. Such safeguards may include:

• encrypted communications
• role-based access controls
• audit logging
• administrative access restrictions
• infrastructure monitoring
• security reviews

11.3. No electronic system is completely secure, and we cannot guarantee absolute security.

12. Data Breach Notification

12.1. Where required by applicable law, INFLUSWAY FZCO may notify competent authorities and affected Users in connection with qualifying personal data breaches.

12.2. Notification timing and content will be handled in accordance with applicable legal requirements, including UAE PDPL, GDPR, DPDP Act, or other applicable privacy laws where relevant.

13. User Rights and DSAR Process

13.1. Subject to applicable law, Users may have rights including:

• access
• correction
• deletion
• restriction
• portability
• objection
• withdrawal of consent
• complaint to a competent authority

13.2. Rights requests may be submitted to: contact@influsway.com

13.3. We may require identity verification before responding to a request.

13.4. We aim to respond within timelines required by applicable law.

13.5. We may refuse or limit requests where permitted by law, including where a request is manifestly unfounded, excessive, legally restricted, or conflicts with legal retention obligations.

14. Children

The Platform is not intended for individuals under eighteen (18) years of age. Users must be at least eighteen (18) to register or use the Platform.

15. Third-Party Services

The Platform may integrate with third-party services, including payment processors, analytics providers, social media platforms, and email infrastructure providers. Such services may operate under their own privacy policies and terms.

16. Policy Updates

16.1. We may update this Privacy Policy from time to time to reflect legal, operational, technical, or Platform changes.

16.2. Material changes may be communicated through email, Platform notices, or updated effective dates.

17. Contact

INFLUSWAY FZCO IFZA Business Park, DDP PO Box 342001 Dubai, United Arab Emirates Email: contact@influsway.com