Last Updated: April 25, 2025
This policy explains the rights of individuals regarding the collection, use, sale, and sharing of their personal information. We may update and make changes to this policy, so we encourage you to review it periodically.
Through our services, we process data about three types of users: Creators, Advertisers and Recruiters who sign up to our Terms of Service (“Users”) as well as potential users.
Depending on the services we provide to you and how you interact with us, we may collect, use, store, and transfer different kinds of personal data about you. You aren’t required to provide us with personal data. However, if you don’t share certain data with us, we may not be able to provide you with our Services or respond to your requests.
We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.
It would be helpful to start by explaning some key terms used in this policy:
We, us, our
Postr Technologies, Inc. (“Postr”), 108 Lakeland Ave. Dover, Delaware 19901
Data Protection Officer
Mike Diamond
privacy@postr.com
(410) 916-9099
Personal information
Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household.
Sensitive personal information
Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, and citizenship or immigration status.
Biometric Information
An individual's physiological, biological, or behavioral characteristics, including information about an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
We may collect the following categories and specific types of personal information:
Categories of Personal Information
Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
First Name, Last Name, Birth Date
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Phone, Company Name and EIN, Title, Email, Social Media Handles, Address: (Physical, Banking, Shipping), Bank account and other payment information
Characteristics of protected classifications under state or federal law
Followers by age, gender
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Friends list (who you have invited and who has accepted), petitions and content reviews, social media accounts and channels and profiles and descriptions, job preferences, jobs viewed and jobs performed
Biometric information
Face scan information, information from driver license or passport
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement)
Post metadata and captions/descriptions, timing of a post, partial or full content of comments left by community members, including your responses, average engagement rate, impressions, followers and counts of views, likes, comments, shares, reshares and reposts, total views, number of followers, job preferences, jobs viewed, jobs performed
Geolocation data
Location and geographical distribution
Audio, electronic, visual, thermal, olfactory, or similar information
We record sessions you have with the platform but tag and redact fields that contain Personal Information
Professional or employment-related information
Company, company EIN, title, company email
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)
None
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
None
Sensitive Personal Information defined as health information, biometric information, financial information: racial or ethnic origin, or political opinions
Bank account details, credit card numbers, and financial history, racial or ethnic origin
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for
Our reasons
To provide products and/or services to you
For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or your organization
For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity
Screening for financial and other sanctions or embargoes
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use
For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information
For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems
For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
Updating and enhancing customer records
For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to:
—existing and former customers;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
Credit reference checks via external credit reference agencies
For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, e.g., for accreditations and the audit of our accounts
For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations
For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.
We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. The recipient of the information will be bound by confidentiality obligations.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, including after your request to delete it, we will delete or anonymize it.
Right to Be Informed
The right to know or be notified about the collection and use of your personal information
Right to Access
The right to be provided with a copy of your personal information (the right of access)
Right to Rectification
The right to require us to correct any mistakes in your personal information
Right to be Forgotten
The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing
The right to require us to restrict processing of your personal information in certain circumstances, e.g., if you contest the accuracy of the data
Right to Data Portability
The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object
The right to object:
At any time to your personal information being processed for direct marketing (including profiling)
In certain other situations to our continued processing of your personal information, e.g., processing carried out for our legitimate interests
Right Not to be Subject to Automated Individual Decision-Making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.
These transfers are subject to special rules under European and UK data protection law.
For non-EEA countries that do not have the same data protection laws as the United Kingdom and EEA, we will ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses or if you would like further information, please contact our Data Protection Officer (see “How To Contact Us” below).
You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You
You have the right to know, and request disclosure of:
• The categories of personal information we have collected about you, including sensitive personal information;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting, selling, or sharing personal information;
• The categories of third parties to whom we disclose personal information, if any; and
• The specific pieces of personal information we have collected about you.
Please note that we are not required to:
• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
• Provide the personal information to you more than twice in a 12-month period.
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose
We do not sell your Personal Information. We may share, or disclose your Personal Information to a third party for a business purpose, in which case you have the right to know:
• The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and
• The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.
You have the right to opt-out of the sharing of your personal information for targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. This may result in your inability to use our services.
To opt-out of the sharing of your personal information, please email privacy@postr.com
Right to Limit Use of Sensitive Personal Information
You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
To perform the following services:
(1) Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;
(2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, if the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business;
(3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and
(4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and
As authorized by further regulations.
You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.
To limit the use of your sensitive personal information, email us at privacy@postr.com
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
• Delete your personal information from our records; and
• Direct any service providers or contractors to delete your personal information from their records.
• Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.
Please note that we may not delete your personal information if it is reasonably necessary to:
• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right of Correction
If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation
You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:
• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of Services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.
If you would like to exercise any of your rights as described in this Privacy Policy, you can email us at privacy@postr.com.
Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly you will need to provide us with:
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.
Third-Party Websites/Applications. The Services may contain links to other websites/ applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
Please contact us and/or our Data Protection Officer if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
Postr Technologies, Inc. (“Postr”), 108 Lakeland Ave. Dover, Delaware 19901
Mike Diamond, Data Protection Officer
(410) 916-9099
© Postr Technologies, Inc. 2025.