Influsway Privacy Policy — International

Entity: INFLUSWAY FZCO
Domain: influsway.com
Effective Date: 2 June 2026
Version: 2026-06-V4-PRIVACY-COM

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

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

By accessing or using the Platform, you acknowledge that you have read and understood this Policy.

1. INTRODUCTION
   1. INFLUSWAY FZCO (“Influsway”, “we”, “our”, or “us”) operates an international influencer marketing marketplace connecting Businesses and Influencers across multiple jurisdictions.
   2. This Privacy Policy explains how we collect, use, process, disclose, store, and protect personal data when Users access or use the Platform.
   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
   1. Registration Data
      • full name
      • email address
      • mobile number
      • social media usernames
      • account credentials
      • business details
      • billing details
   2. Identity and Compliance Data
      • 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. Campaign Data
      • Campaign briefs
      • Deliverables
      • approval records
      • revision requests
      • dispute materials
      • communication history
      • timestamps and audit logs
   4. Wallet and Payment Data
      • wallet balances
      • payout records
      • transaction references
      • payment metadata
      • refund records
      • chargeback or dispute records
   5. Technical and Usage Data
      • IP addresses
      • browser and device information
      • session logs
      • usage analytics
      • approximate geolocation
      • crash logs
      • security logs
   6. Social Media API Data
      • profile information
      • engagement metrics
      • follower counts
      • media insights
      • audience analytics
      • performance data
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
5. AUTOMATED PROCESSING AND PLATFORM SCORING
   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
   2. Automated processing may affect User visibility, discoverability, and marketplace opportunities on the Platform.
   3. Users may contact us to request more information about automated processing that materially affects them.
6. HOW WE USE PERSONAL DATA
   • 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
7. COOKIES AND TRACKING TECHNOLOGIES
   1. The Platform may use cookies and similar technologies.
   2. Tools used may include:
      • Google Analytics 4
      • Meta Pixel
      • similar analytics or advertising technologies
   3. Users may accept or reject non-essential cookies where required by law.
   4. Users may also manage cookies through browser settings.
8. INTERNATIONAL DATA TRANSFERS

   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
9. DATA SHARING AND SUB-PROCESSORS

   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

   We do not sell personal data.

10. DATA RETENTION
    1. Financial and transactional records may be retained for up to seven (7) years or longer where required by law.
    2. Account information may be retained while the account remains active and for a reasonable period after account closure.
    3. Campaign records, Deliverables, approval logs, dispute materials, and audit records may be retained.
    4. Technical logs may be retained for security, diagnostics, fraud prevention, and audit purposes.
11. DATA SECURITY
    1. We implement reasonable technical and organizational safeguards designed to protect personal data.
    2. Such safeguards may include:
       • encrypted communications
       • role-based access controls
       • audit logging
       • administrative access restrictions
       • infrastructure monitoring
       • security reviews
    3. No electronic system is completely secure, and we cannot guarantee absolute security.
12. DATA BREACH NOTIFICATION
    1. Where required by applicable law, INFLUSWAY FZCO may notify competent authorities and affected Users regarding qualifying personal data breaches.
    2. Notification timing and content will be handled in accordance with applicable legal requirements.
13. USER RIGHTS AND DSAR PROCESS

    Subject to applicable law, Users may have rights including:

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

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

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.

16. POLICY UPDATES
    1. We may update this Privacy Policy from time to time to reflect legal, operational, technical, or Platform changes.
    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