Global Data Processing Agreement

This Data Processing Agreement (DPA) forms part of the CleerCut Creator Agreement and applies when CleerCut processes Personal Data on behalf of users. By using the CleerCut platform, users agree to this Data Processing Agreement.

For purposes of applicable data protection laws:

• The user of the CleerCut platform acts as the Data Controller
• CleerCut acts as the Data Processor

The Data Controller determines the purposes for which Personal Data is provided to CleerCut through use of the platform. CleerCut processes Personal Data solely to provide and operate the platform services.

CleerCut may process Personal Data including:

• Account information
• Contact details
• Campaign and collaboration data
• Communication records within the platform
• Usage and technical data

The categories of data subjects may include Creators, Client representatives, and platform users.

CleerCut processes Personal Data to:

• Provide and operate the platform
• Facilitate collaborations between Creators and Clients
• Enable platform communication and campaign management
• Process payments through third party providers
• Maintain platform security and fraud prevention

Processing is conducted in accordance with the CleerCut Privacy Policy.

CleerCut may engage third party service providers to support operation of the platform. These may include providers for:

• Cloud hosting infrastructure
• Payment processing
• Security and analytics tools

CleerCut requires such subprocessors to implement appropriate data protection safeguards.

CleerCut implements reasonable technical and organizational safeguards designed to protect Personal Data. These safeguards may include:

• Encryption of data in transit
• Access controls limiting access to authorized personnel
• Infrastructure security monitoring
• Security incident response procedures

Further details are described in the CleerCut Security Policy.

Where required by applicable law, CleerCut will assist users in responding to requests from data subjects regarding their Personal Data. Such requests may include:

• Access
• Correction
• Deletion
• Restriction of processing

Requests may be submitted through hello@cleercut.com

CleerCut retains Personal Data only for as long as necessary to provide services and comply with legal obligations. Data retention practices are described in the CleerCut Data Retention Policy.

CleerCut may transfer Personal Data to service providers located in different jurisdictions. Where required by applicable law, CleerCut will implement appropriate safeguards designed to protect such transfers.

In the event of a security incident affecting Personal Data, CleerCut will investigate the incident and take reasonable steps to mitigate the impact. CleerCut will notify affected users when required by applicable law.

This Data Processing Agreement forms part of the CleerCut Creator Agreement. If any conflict exists between this DPA and the Creator Agreement, the Creator Agreement will govern unless otherwise required by law.