Last updated: Sep 8, 2025

Summary

This Zurno Influencer Program Privacy Policy (“Zurno Influencer Program Privacy Policy”) sets out how we collect, use, share, and otherwise process personal information we collect from you, or that you provide to us, if you participate in the Zurno Influencer Program as an Influencer (“Zurno Influencer”) who promotes products offered by Zurno.

This Privacy Policy incorporates and supplements the Zurno App Privacy Policy. This means that, for example, personal information we collect through your participation in the Zurno Influencer Program may also be used for the purposes described in the Zurno App Privacy Policy. To the extent applicable, information collected via the Zurno App platform (“Platform”) can also be processed as described in this Zurno Influencer Program Privacy Policy.

For more details, please review the Zurno App Privacy Policy, which also includes important information on your rights and how and where we store and protect your personal information. Any capitalized terms not defined in this Zurno Influencer Program Privacy Policy have the meaning given to them in the Zurno App Privacy Policy.

 

What information do we collect about you through the Zurno Influencer Program?

Information You Provide

When you participate in the Zurno Influencer Program, we may collect the following information:

• Your full name and date of birth

• Your phone number and email address

• Your social media URLs linked to your application

• Your billing and shipping addresses

• A copy or photo of your passport, government-issued ID card, or driver’s license

• Your bank account information

• Your tax information, such as VAT or TIN (or place of birth if no TIN is available)
  

Automatically Collected Information

We also collect the following information automatically when you participate:

• Products you receive as samples and/or choose to promote, including related information on sales, commissions, and performance metrics for the relevant videos and livestreams you create
  

• Your ratings, rankings, and aggregated information about your followers, such as demographic insights
  

• Content insights, such as why your content is performing well on the Platform
  

Information From Other Sources

We may also receive information from third parties, such as:

• Payment providers
  

• Identity verification providers
  

 

How do we use information collected about you?

We process your information for the following purposes:

• To check your eligibility to participate in the Zurno Influencer Program and facilitate commission payments
  

• To personalize and customize features and content (e.g., showing products in your Influencer Dashboard that we think may interest you)
  

• To comply with our legal obligations
  

 

Who do we share your information with?

Service Providers

We share the information you provide with third-party service providers (such as payment processors and identity verification providers) to confirm your eligibility and process commission payments.

Legal Obligations and Rights

We may access, preserve, and share your information with law enforcement agencies, public authorities (e.g., tax authorities), entities within our corporate group, researchers, copyright holders, or other third parties if we have a good faith belief that it is necessary to:

• Comply with applicable laws (including tax collection and reporting requirements), legal processes, or government requests consistent with internationally recognized standards
  

• Protect the rights, property, and safety of our users, copyright holders, or others, including to protect life or prevent imminent bodily harm (for example, by providing your phone number to law enforcement in an emergency)
  

• Investigate potential violations of, and enforce, our Terms, Guidelines, or other applicable terms, policies, or standards
  

• Detect, investigate, prevent, or address fraudulent, misleading, infringing, or illegal activity

 

Jurisdiction-Specific Terms

Brazil

If you are using the Zurno Influencer Program in Brazil, the following additional terms apply. For further information on how to exercise your rights, please refer to the Zurno App Privacy Policy.

Our legal bases for processing your information:
When we process your personal information, we rely on the following legal bases:

• Execution of a contract: For example, to administer and provide the Zurno Influencer Program for you to participate as a creator; to facilitate payment processing; to provide you with user support, including troubleshooting and service-related notifications.

• Legitimate interest: For example, to keep the Zurno Influencer Program safe and secure, including conducting due diligence, verifying accounts, and detecting and preventing abuse, harmful activity, fraud, spam, and other illegal activities; to send marketing communications, including promotional materials that may be relevant or of interest; and to improve our review process for enforcing compliance with our policies.

• Compliance with a legal or regulatory obligation, or an authority order: We may share your data with relevant authorities or regulatory bodies as required to comply with legal obligations or a court order.

European Economic Area and UK

(If you are located in the EEA or the UK, the section below applies to you.)

Our legal bases and how we process your information
When you participate in the Zurno Influencer Program, we process your information based on the following legal bases:

Contractual Necessity

We use Information You Provide and Automatically Collected Information where it is necessary to perform the Influencer Terms of Use and other relevant terms and policies. This means we use your information to:

• Check eligibility and facilitate commission payments
  

• Personalize features and content in the Zurno Influencer Dashboard

Legitimate Interests

We use your information when necessary to achieve legitimate interests (ours, yours, or third parties’) that are not outweighed by your rights and freedoms. Examples include:

• Enabling Agencies and Partners to discover your profile before you link with them

• Sharing inspirational creator content and performance data to help the community improve

• Sharing tax information within our corporate group for compliance purposes

Compliance with a Legal Obligation

We may use or share your information, including tax details, to comply with obligations such as tax reporting, anti-money laundering, safety requirements, or valid legal requests from regulators or courts.

Data Transfers

We may transfer your information outside of your country of residence, including to Sellers, service providers, and agencies. Where required, we rely on adequacy decisions, standard contractual clauses, or Article 49 GDPR exceptions to ensure appropriate protection.