Privacy Policy

This Privacy Policy explains how Vinculor LLC ("Vinculor," "we," "us," or "our") collects, uses, discloses, and protects information in connection with the Vinculor website, applications, and related services (the "Platform"). This Policy applies to Businesses, Creators, and visitors to the Platform. By using the Platform, you acknowledge the practices described in this Policy.

This Policy should be read together with our Terms of Service. Capitalized terms not defined here have the meaning given in the Terms of Service.

1. Information We Collect

1.1 Information You Provide Directly

• Account information: name, email address, password (stored in hashed form), account type (Business or Creator).
• Profile information: business name, business description, and — for Creators — self-reported links to TikTok, Instagram, and YouTube profiles (see Section 5 of the Terms of Service; these links are not independently verified by Vinculor).
• Listings, submissions, and negotiation content: listing descriptions, proposed and final compensation terms, submitted content or links to content, and written justifications submitted during negotiation.
• Messages: content of messages exchanged with other Users through the Platform's messaging feature.
• Dispute-related information: statements, evidence, or descriptions submitted when flagging or responding to a dispute.
• Communications with us: information you provide when contacting support.

1.2 Information Collected Automatically

• Usage data: pages viewed, features used, timestamps, and general interaction data with the Platform.
• Device and log data: IP address, browser type, operating system, and similar technical identifiers.

Vinculor does not currently use third-party advertising or analytics cookies. If this changes, this section will be updated accordingly, along with any required consent mechanisms.

1.3 Information From Third Parties. When you connect a payout or checkout method through Stripe, Stripe collects and processes sensitive financial and identity-verification information directly (see Section 3). Vinculor receives limited information back from Stripe — such as account status, whether onboarding is complete, and high-level transaction confirmations — but does not receive or store full bank account numbers, card numbers, or government-issued identification submitted to Stripe.

2. How We Use Information

We use the information described above to:

• Operate, maintain, and improve the Platform, including listings, messaging, negotiation, notifications, and dispute tools;
• Facilitate transactions between Businesses and Creators, including passing necessary information to Stripe to process payments and payouts;
• Communicate with you, including sending notifications about listing activity, submissions, messages, escrow status, and disputes;
• Maintain the security and integrity of the Platform, including detecting fraud, abuse, and violations of our Terms of Service;
• Comply with legal obligations, including tax reporting where applicable; and
• Analyze aggregated, de-identified usage trends to improve the Platform.

We do not use the content of your private messages or dispute submissions for advertising purposes.

3. Payment Information and Stripe

Vinculor uses Stripe, Inc. as its payment processor for both Business escrow funding (via Stripe Checkout) and Creator payouts (via Stripe Connect Express). When you provide payment or banking information, or complete identity verification (KYC) as part of Creator payout onboarding, that information is submitted directly to Stripe and is governed by Stripe's own privacy policy, available at stripe.com/privacy.

Vinculor does not directly store full payment card numbers, bank account numbers, or government identification documents submitted through Stripe's onboarding or checkout flows.

4. How We Share Information

We do not sell your personal information. We share information only in the following circumstances:

• With other Users, as necessary for the Platform to function — for example, a Creator's self-reported profile links and submission content are visible to the Business reviewing that submission, and vice versa; messages are visible to the participants in that thread.
• With service providers who perform services on our behalf, including payment processing (Stripe), hosting and infrastructure (e.g., Netlify), and similar vendors, under contractual obligations to protect your information and use it only for the purposes we specify.
• For legal reasons, including to comply with a subpoena, court order, or other legal process, or to protect the rights, property, or safety of Vinculor, our Users, or the public.
• In connection with a business transaction, such as a merger, acquisition, or sale of assets, subject to standard confidentiality protections.
• With your consent, or at your direction.

5. Data Retention

We retain personal information for as long as necessary to provide the Platform, comply with legal obligations (including tax and financial recordkeeping requirements associated with payment transactions), resolve disputes, and enforce our agreements. Retention periods vary based on the type of data and applicable legal requirements.

6. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction, including encryption of data in transit and hashed storage of account passwords. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Your Privacy Rights

Depending on where you live, you may have certain rights regarding your personal information, which may include the right to:

• Access the personal information we hold about you;
• Correct inaccurate personal information;
• Delete your personal information, subject to legal exceptions (e.g., records we must retain for tax or legal compliance);
• Opt out of certain processing, such as targeted advertising or the "sale" or "sharing" of personal information, to the extent applicable — Vinculor does not currently sell personal information;
• Appeal a denied privacy request, in applicable jurisdictions.

7.1 California Residents. Vinculor does not currently meet the applicability thresholds under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), but voluntarily extends the rights described in this section to California residents as a matter of policy. This will be reviewed and updated as the business grows.

7.2 Colorado Residents. Vinculor does not currently meet the applicability thresholds under the Colorado Privacy Act ("CPA"), but as a Colorado company, voluntarily extends the rights described in this section — including rights to access, correct, delete, and obtain a portable copy of your personal data — to Colorado residents as a matter of policy. This will be reviewed and updated as the business grows.

7.3 Other States. Depending on where you live, additional state privacy laws may apply. Vinculor will update this Policy as needed to reflect applicable requirements as our user base grows.

To exercise any applicable rights, contact us using the information in Section 10. We will verify your identity before fulfilling a request.

8. Children's Privacy

The Platform is not directed to, and is not intended for use by, anyone under 18 years of age. We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected personal information from someone under 18, we will take steps to delete it. If you believe a minor has provided us with personal information, please contact us.

9. International Users

Vinculor's Platform is currently intended for use within the United States. If Vinculor begins serving users outside the United States, this Policy will be updated to include the necessary safeguards before doing so.

10. Changes to This Policy; Contact Us

We may update this Privacy Policy from time to time. Material changes will be communicated through the Platform or by email prior to taking effect. The "Last Updated" date at the top of this Policy reflects the most recent revision.

Questions about this Privacy Policy, or requests to exercise your privacy rights, can be directed to support@vinculor.com, or by mail to Vinculor LLC, 12091 W Center Pl, Lakewood, CO 80228.