Privacy Policy

Effective Date: January 12, 2026 · Last Updated: January 12, 2026

1. Introduction

Setup101 Ltd. ("Setup101," "we," "us," or "our") operates the Setup101 platform, including our website at setup101.io, mobile applications, and related services (collectively, the "Platform"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our Platform.

Setup101 is a marketplace platform that connects content creators ("Creators") with brands and sponsors ("Sponsors") for sponsored content opportunities. We take your privacy seriously and are committed to protecting your personal data in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR), the UK Data Protection Act, and the California Consumer Privacy Act (CCPA).

By using our Platform, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controllers

For users in the European Economic Area (EEA), Switzerland, and the United Kingdom:

Setup101 Ltd. (Ireland) acts as the data controller

For users in the United States and other regions:

Setup101 Inc. (USA) acts as the data controller

Contact: privacy@setup101.io

3. Information We Collect

3.1 Information You Provide Directly

Account Information:

Name, email address, and password
Profile photo and biography
Date of birth (for age verification)
Country and timezone
Social media handles and links

Creator-Specific Information:

Setup descriptions, photos, and videos
Product and equipment details
Categories and tags
Portfolio and media content
Payment and payout information (processed via third-party providers)

Sponsor-Specific Information:

Company name and business details
Billing and payment information
Campaign briefs and brand assets
Product information for sponsored placements

Communications:

Messages exchanged through our Platform
Customer support inquiries
Survey responses and feedback

3.2 Information Collected Automatically

Device and Technical Information:

Device type, operating system, and browser type
Unique device identifiers
IP address and approximate location
Mobile network information

Usage Information:

Pages and features accessed
Time spent on the Platform
Click patterns and navigation paths
Search queries
Content interactions (views, saves, shares)

Cookies and Tracking Technologies:

Essential cookies for Platform functionality
Analytics cookies to understand usage patterns
Preference cookies to remember your settings
Marketing cookies for relevant advertising (with consent)

See Section 10 for detailed cookie information.

3.3 Information from Third Parties

Social Media Platforms:

When you connect accounts (Instagram, TikTok, YouTube, etc.), we may receive profile information, follower counts, and engagement metrics

Payment Processors:

Transaction confirmations and payment status (we do not store full payment card details)

Analytics Partners:

Aggregated usage data and demographic insights

Identity Verification Services:

Verification results for fraud prevention

4. How We Use Your Information

We use your information for the following purposes:

4.1 Providing and Improving the Platform

Creating and managing your account
Facilitating connections between Creators and Sponsors
Processing transactions and payments
Displaying your public profile and setups
Personalizing your experience and recommendations
Analyzing usage to improve features and performance

4.2 Communications

Sending service-related notifications
Responding to your inquiries and support requests
Providing updates about campaigns and sponsorships
Sending marketing communications (with your consent)

4.3 Safety and Security

Detecting and preventing fraud, abuse, and security incidents
Enforcing our Terms of Service and Community Guidelines
Verifying user identity where required
Protecting the rights and safety of users and third parties

4.4 Legal Compliance

Complying with applicable laws and regulations
Responding to legal requests and government inquiries
Establishing, exercising, or defending legal claims

4.5 Advertising and Analytics

Displaying relevant advertisements (where applicable)
Measuring advertising effectiveness
Understanding user demographics and preferences

5. Legal Bases for Processing (EEA/UK Users)

We process your personal data based on the following legal grounds:

Account creation and Platform operation — Performance of contract
Processing payments — Performance of contract
Customer support — Performance of contract
Security and fraud prevention — Legitimate interests
Platform improvement and analytics — Legitimate interests
Marketing communications — Consent
Legal compliance — Legal obligation

You may withdraw consent at any time where processing is based on consent.

6. How We Share Your Information

6.1 Public Information

Your public profile, setups, and any content you choose to make public are visible to other users and may be indexed by search engines.

6.2 Between Creators and Sponsors

When you engage in a sponsorship arrangement, relevant information is shared between parties to facilitate the collaboration, including:

Profile and contact information
Campaign details and requirements
Payment amounts and status
Performance metrics

6.3 Service Providers

We share information with trusted third-party service providers who assist in operating our Platform, including:

Cloud hosting and storage providers
Payment processors (Stripe, PayPal)
Email and communication services
Analytics and monitoring tools
Customer support platforms

These providers are contractually obligated to protect your data and use it only for specified purposes.

6.4 Law Enforcement and Legal Requests

We may disclose your information to law enforcement agencies, government authorities, courts, or other parties when we believe in good faith that disclosure is necessary to:

Comply with applicable laws, regulations, or valid legal processes (such as subpoenas, court orders, or search warrants)
Respond to requests from law enforcement or government agencies
Protect the safety, rights, or property of Setup101, our users, or the public
Prevent or investigate possible wrongdoing, fraud, or security issues
Enforce our Terms of Service or other agreements

We will attempt to notify you of legal demands for your information when appropriate, unless prohibited by law or court order, or when the request is an emergency.

6.5 Business Transfers and Corporate Transactions

In the event of a merger, acquisition, bankruptcy, reorganization, dissolution, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. In such cases:

The acquiring entity will be bound by the terms of this Privacy Policy
We will notify you via email and/or prominent notice on our Platform before your information is transferred
You will have the opportunity to delete your account before the transfer

6.6 Investors and Due Diligence

In connection with financing, investment, or due diligence activities, we may share:

Aggregated and anonymized data that does not identify individual users
Business metrics and statistics about Platform usage and performance

We do NOT share personally identifiable information with investors, potential investors, or their affiliated companies without your explicit consent, except as part of a completed business transfer (see Section 6.5).

6.7 Affiliated Companies

We may share information with our subsidiaries and affiliated companies that are under common ownership or control. These affiliates are bound by this Privacy Policy and will only use your information as described herein.

We do NOT sell, rent, or share your personal information with investors' portfolio companies, affiliated investment entities, or other third-party businesses for their own marketing or commercial purposes.

6.8 With Your Consent

We may share your information for other purposes with your explicit consent. You can withdraw consent at any time, though this will not affect the lawfulness of processing before withdrawal.

7. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. When we transfer data outside the EEA, UK, or Switzerland, we ensure appropriate safeguards are in place, including:

Standard Contractual Clauses approved by the European Commission
Adequacy decisions by relevant authorities
Other lawful transfer mechanisms

8. Data Retention

We retain your personal data for as long as necessary to:

Provide our services and maintain your account
Comply with legal obligations
Resolve disputes and enforce agreements
Meet legitimate business needs

Specific retention periods:

Active account data: Duration of account plus 3 years
Transaction records: 7 years (legal requirement)
Customer support records: 3 years from resolution
Marketing preferences: Until consent withdrawn
Analytics data: 26 months (anonymized thereafter)

You may request deletion of your account and data at any time, subject to legal retention requirements.

9. Your Rights and Choices

9.1 All Users

Access: Request a copy of your personal data
Correction: Update or correct inaccurate information
Deletion: Request deletion of your account and data
Data Portability: Receive your data in a portable format
Objection: Object to certain processing activities
Restriction: Request limited processing of your data
Withdraw Consent: Withdraw previously given consent

To exercise these rights, contact us at privacy@setup101.io or use the settings in your account.

9.2 Additional Rights for EEA/UK Users

You have the right to lodge a complaint with your local data protection authority.

9.3 Additional Rights for California Users

Under the CCPA, you have the right to:

Know what personal information is collected
Know whether your data is sold or disclosed
Opt out of the sale of personal information
Access your personal information
Request deletion of your information
Non-discrimination for exercising your rights

We do not sell your personal information.

10. Cookies and Tracking Technologies

10.1 Types of Cookies We Use

Strictly Necessary Cookies — required for Platform functionality. Cannot be disabled.

Authentication and session management
Security features
Load balancing

Performance and Analytics Cookies — help us understand how users interact with our Platform.

Google Analytics
Mixpanel
Error tracking services

Functional Cookies — remember your preferences and settings.

Language preferences
Display settings
Recently viewed content

Marketing Cookies — used to deliver relevant advertisements.

Social media pixels
Advertising networks
Retargeting services

10.2 Managing Cookies

You can manage cookie preferences through:

Our cookie consent banner
Your browser settings
Third-party opt-out tools (e.g., NAI, DAA)

Note: Disabling certain cookies may affect Platform functionality.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

Encryption of data in transit (TLS/SSL) and at rest
Regular security assessments and penetration testing
Access controls and authentication requirements
Employee training on data protection
Incident response procedures

While we strive to protect your information, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

12. Children's Privacy

Setup101 is not intended for users under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected data from a child under 13, we will take steps to delete such information.

Users between 13 and 18 should review this Privacy Policy with a parent or guardian.

13. Third-Party Links and Services

Our Platform may contain links to third-party websites, services, or integrations. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you access.

14. Automated Decision-Making

14.1 How We Use Automated Processing

We may use automated systems to:

Detect and prevent fraud and abuse
Recommend content and creators to users
Match Sponsors with relevant Creators
Moderate content for policy violations

14.2 Your Rights Regarding Automated Decisions

Under GDPR, you have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. If you believe an automated decision has significantly affected you, you may:

Request human review of the decision
Express your point of view
Contest the decision

15. Marketing Communications

15.1 Types of Communications

We may send you:

Service Communications: Account updates, security alerts, transaction confirmations (required for service operation)
Marketing Communications: Newsletters, promotions, new features (consent-based)

15.2 Your Choices

You can opt out of marketing communications at any time by:

Clicking "unsubscribe" in any marketing email
Adjusting preferences in your account settings
Contacting us at privacy@setup101.io

Opting out of marketing will not affect service-related communications.

15.3 CAN-SPAM Compliance (US Users)

In compliance with the CAN-SPAM Act:

We will not use false or misleading header information
We will identify messages as advertisements where required
We will include our physical address in emails
We will honor opt-out requests within 10 business days
We will not sell or transfer email addresses to third parties for their marketing

16. Platform Transparency (EU Digital Services Act)

For users in the European Union, in compliance with the Digital Services Act (DSA):

16.1 Content Moderation

We use a combination of automated tools and human review to moderate content
Our Community Guidelines explain what content is prohibited
You can appeal content moderation decisions through our support system

16.2 Recommender Systems

Our Platform uses algorithms to recommend content based on:

Your stated interests and categories
Content you have engaged with
Popularity and recency of content
Creator performance metrics

You can influence recommendations by:

Updating your interests in account settings
Using the "not interested" feature on content
Following or unfollowing specific creators

16.3 Reporting Illegal Content

EU users can report illegal content through our reporting tools. We will:

Acknowledge receipt of your report
Review the content promptly
Notify you of our decision
Provide information on appeal options

16.4 Transparency Reports

We publish periodic transparency reports detailing:

Content moderation actions taken
Government requests received
Appeals and outcomes

17. Supervisory Authorities (EEA/UK Users)

17.1 Lead Supervisory Authority

For GDPR purposes, our lead supervisory authority is:

Data Protection Commission (Ireland), 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland. Website: www.dataprotection.ie

17.2 Your Right to Complain

If you are unsatisfied with how we handle your data or respond to your requests, you have the right to lodge a complaint with:

Our lead supervisory authority (Ireland DPC)
The supervisory authority in your country of residence
The supervisory authority where the alleged violation occurred

We encourage you to contact us first at dpo@setup101.io so we can address your concerns.

17.3 UK Users

For users in the United Kingdom, you may also contact:

Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom. Website: www.ico.org.uk

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will notify you of material changes by:

Posting the updated policy on our Platform
Sending you an email notification
Displaying a prominent notice in our app

Your continued use of the Platform after changes become effective constitutes acceptance of the revised Privacy Policy.

19. Do Not Track Signals

Some browsers have a "Do Not Track" (DNT) feature that signals to websites that you do not want your online activity tracked. There is currently no universally accepted standard for how to respond to DNT signals.

At this time, we do not respond to DNT signals. However, you can manage your privacy preferences through:

Cookie settings on our Platform
Browser privacy settings
Third-party opt-out tools

We will update this policy if a standard for DNT is established.

20. State-Specific Privacy Rights (US)

20.1 Virginia, Colorado, Connecticut, and Utah Residents

If you reside in Virginia, Colorado, Connecticut, or Utah, you have rights similar to California residents, including:

Right to access your personal data
Right to delete your personal data
Right to correct inaccurate data
Right to opt out of targeted advertising
Right to opt out of the sale of personal data (we do not sell data)
Right to appeal our decisions regarding your requests

20.2 Nevada Residents

Nevada residents may opt out of the sale of personal information. We do not currently sell personal information as defined under Nevada law.

21. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

General Privacy Inquiries: privacy@setup101.io
Data Protection Officer: dpo@setup101.io
Data Subject Requests: privacy@setup101.io — please include "Data Subject Request" in the subject line.

Response Times. We aim to respond to all privacy inquiries within:

30 days for GDPR requests (extendable by 60 days for complex requests)
45 days for CCPA requests (extendable by 45 days with notice)
10 business days for general inquiries

This Privacy Policy was last updated on January 12, 2026.