Privacy Policy

The data controller responsible for your personal data is Act1 LLC FZE, a company registered in the United Arab Emirates, operating the Collabfront marketplace platform. We are committed to compliance with UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection ("UAE PDPL") and any applicable implementing regulations, as well as other applicable data protection laws in the jurisdictions in which we operate, including Lebanon.

For all data protection enquiries, requests, or complaints, please contact: info@collabfront.app

This Privacy Policy applies to all individuals who interact with the Platform, including:

• Brands and agencies that register to discover creators, post campaigns, and manage collaborations.
• Creators who register to offer their services, build their profiles, and receive bookings.
• Visitors who access the Platform without registering an account.

Our Platform is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that personal data has been collected from a person under 18 without appropriate consent, we will take prompt steps to delete it and close the associated account.

3.1 Information You Provide Directly

We collect the following categories of personal data that you provide when registering for or using the Platform:

• Identity Information: Full name, email address, telephone number, and social media handles.
• Identity Verification (Creators only): A copy of a valid government-issued identity document. This is collected solely to verify your identity and to comply with applicable financial and regulatory requirements before processing payouts. This data is stored in a secure, encrypted environment with access strictly limited to authorised personnel. It is not shared with Brands, other Creators, or any third party except where expressly required by applicable law. Identity documents are retained for as long as necessary to fulfil the purposes for which they were collected and to satisfy any applicable legal, financial, or regulatory retention obligations.
• Profile and Portfolio Content: Images, videos, biography, service listings, pricing, category tags, engagement metrics, and any other content you choose to upload as part of your public creator or brand profile.
• Payment Information (Brands): Brand payments are collected by Act1 LLC FZE via third-party payment processing services operating to industry-standard security protocols. We do not store your full credit card or bank account details on our servers. Payment data is processed and stored by our payment processor in accordance with applicable PCI-DSS compliance standards.
• Payout Information (Creators): To facilitate payouts, we collect your Whish Money account details (registered name and phone number) or bank account details (IBAN and bank name) as applicable. This information is stored securely and used solely to execute your requested payout.
• Campaign and Brief Information: Details you provide when creating, applying to, or responding to campaigns, including brand names, product descriptions, content requirements, and target audience information.
• Communications: Messages exchanged through the Platform's internal messaging system between Brands, Creators, and Collabfront support.

3.2 Information We Collect Automatically

When you use the Platform, certain technical and behavioural data is collected automatically, including:

• IP address and general geographic location derived from it.
• Browser type, operating system, and device information.
• Pages visited, features used, session duration, click behaviour, and navigation paths.
• Referring URLs and traffic sources.

This data is collected through standard web technologies including cookies, log files, and analytics tools. It is used to operate, secure, and improve the Platform. Details of the specific analytics tools currently in use are available on request by contacting info@collabfront.app.

We process personal data collected through the Platform for the following purposes:

• To create, verify, and manage your account and professional profile.
• To facilitate connections between Brands and Creators, including sharing relevant profile information with the counterparty in a prospective or active collaboration, as necessary to operate the marketplace.
• To process Brand payments securely and hold funds under our payment protection system pending collaboration approval.
• To process Creator payout requests via the applicable transfer method.
• To maintain your professional history on the Platform, including completed collaborations, ratings, reviews, and Creator milestone status.
• To review, moderate, and approve campaigns and content submitted to the Platform.
• To send transactional communications, including booking confirmations, payout notifications, dispute updates, and collaboration status updates.
• To send service-related communications about Platform updates, new features, and policy changes. You may opt out of non-essential communications at any time through your account settings or by contacting us.
• To monitor Platform usage, detect fraud, investigate prohibited activity, and enforce our Terms of Service.
• To comply with our legal, financial, and regulatory obligations in the UAE and Lebanon.

We process your personal data on the following legal grounds:

• Contract Performance: Processing necessary to provide the Platform services you have registered for, including account management, payment processing, and collaboration facilitation.
• Legitimate Interests: Processing carried out in pursuit of our legitimate business interests, including platform security, fraud prevention, product improvement, and business analytics, where such interests are not overridden by your fundamental rights and freedoms.
• Legal Obligation: Processing required to comply with applicable laws, regulatory requirements, or lawful requests from competent authorities in the UAE or Lebanon.
• Consent: Where required by applicable law, we will obtain your explicit consent before processing your personal data for specific purposes. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

We do not sell, rent, or trade your personal data to third parties for their own independent commercial purposes. We share personal data only in the following limited and controlled circumstances:

• With Platform Users: Creator profile information, including name, portfolio content, service categories, engagement data, pricing, and social media handles, is made visible to registered Brand users as a core and necessary function of the marketplace. Brand campaign information is shared with Creators who apply to or are matched with a campaign. By using the Platform and publishing a profile, you consent to this visibility as necessary to facilitate the services.
• With Payment Processors: Payment data is shared with our third-party payment processor solely to process Brand payments securely. Our payment processor operates as an independent data controller under its own privacy policy and is not permitted to use your data for any purpose beyond payment processing.
• With Whish Money (Whish SAL) or Banking Institutions: Creator payout information is shared with the relevant payment provider solely to execute the requested transfer.
• With Service Providers: We may engage trusted third-party service providers to assist in operating, maintaining, and improving the Platform. All service providers are subject to appropriate data processing agreements that restrict their use of your personal data to the services they provide to us.
• For Legal Compliance: We may disclose personal data where required by applicable law, court order, regulatory authority, or a lawful request from a competent government authority in Lebanon or the UAE.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of assets involving Act1 LLC FZE, personal data may be transferred as part of that transaction. In the event of company dissolution, we will take reasonable steps to securely delete or anonymise personal data, or transfer it to a successor entity subject to equivalent protections, in accordance with applicable law.

Creator profiles on the Platform, including name, portfolio content, social media handles, service categories, pricing, and engagement metrics, are visible to registered Brand users as a necessary and core function of the marketplace. By creating and publishing a creator profile on the Platform, you explicitly consent to this level of visibility.

You are solely responsible for the accuracy, legality, and appropriateness of all information included in your public profile. You may update or remove information from your profile at any time through your account settings or by contacting support.

We use cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device that help us maintain session state, remember your preferences, and understand how users interact with the Platform.

We use the following categories of cookies:

• Essential Cookies: Strictly necessary for the Platform to function correctly. These cannot be disabled without materially affecting core Platform functionality.
• Functional Cookies: Used to remember your account preferences and settings to personalise and improve your experience.
• Analytics Cookies: Used to collect anonymised information about usage patterns to help us understand and improve Platform performance. These do not identify you personally.

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain categories of cookies may affect the availability or functionality of some Platform features.

We retain your personal data for as long as your account remains active, in order to maintain your collaboration history, professional reputation, reviews, and platform standing.

If you close your account, we will delete or anonymise your personal data within a reasonable period, except where retention is required to satisfy legal, tax, accounting, audit, or regulatory obligations. Collaboration records, payment receipts, and dispute-related data may be retained for a period consistent with applicable financial record-keeping requirements under UAE and Lebanese law.

Personal data collected for identity verification purposes is retained for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal and regulatory obligations. Access to such data is restricted at all times to authorised personnel only.

We implement appropriate technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, unlawful alteration, or disclosure. Our measures include, without limitation:

• Encrypted storage for sensitive personal and financial data.
• Strict access controls limiting data access to authorised personnel on a need-to-know basis.
• Secure HTTPS connections for all Platform communications.
• Regular review and assessment of our data security practices and infrastructure.

While we take all reasonable precautions, no method of electronic transmission or storage is entirely secure. You are responsible for maintaining the confidentiality of your account credentials. You must notify us immediately at info@collabfront.app if you suspect any unauthorised access to your account or any breach of your credentials.

Subject to applicable law and our ability to verify your identity, you have the following rights with respect to your personal data:

• Right of Access: To request confirmation of whether we process your personal data and, if so, to receive a copy of it.
• Right to Rectification: To request correction of inaccurate, incomplete, or outdated personal data.
• Right to Erasure: To request deletion of your personal data, subject to any applicable legal retention obligations that require us to retain it.
• Right to Object: To object to processing of your personal data based on legitimate interests, or to direct marketing.
• Right to Data Portability: To receive personal data you have provided to us in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please submit a written request to info@collabfront.app. We will acknowledge receipt promptly and respond to verified requests within 30 days. In cases of complexity or volume, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it before the initial 30-day period expires.

As a platform operating primarily across Lebanon and the UAE, your personal data may be processed in either jurisdiction or by service providers operating in other countries. Where personal data is transferred across borders, we take appropriate steps to ensure that such transfers comply with applicable data protection laws and that adequate safeguards are in place to protect your personal information throughout the transfer and in the destination jurisdiction.

Collabfront is committed to full compliance with UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection and any subsequent implementing regulations issued thereunder. In the event of a personal data breach that is reasonably likely to result in a risk of harm to affected individuals, Collabfront will take prompt and appropriate action in accordance with its obligations under the UAE PDPL, including notification to the relevant regulatory authority and to affected data subjects as required by law and within the timeframes prescribed.

The Platform may contain links to third-party websites, platforms, or services, including social media platforms. Collabfront is not responsible for the privacy practices, data handling, or content of any third-party services. We strongly encourage you to review the privacy policies of any third-party services you access through or in connection with the Platform before providing them with your personal data.

The Platform is strictly intended for individuals aged 18 and over. We do not knowingly collect, process, or retain personal data from individuals under the age of 18. If you are a parent or guardian and believe that a minor has provided personal data to us without your consent, please contact us immediately at info@collabfront.app and we will take prompt steps to delete the relevant data.

We reserve the right to update this Privacy Policy at any time to reflect changes in our data practices, Platform features, or applicable law. Material changes will be communicated to registered Users via email or in-app notification before taking effect. Non-material clarifications may be made without prior notice. The date at the top of this document indicates when it was last updated. Continued use of the Platform following notification of any changes constitutes your acceptance of the revised Policy.

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

Collabfront / Act1 LLC FZE
Email: info@collabfront.app
Website: www.collabfront.app

We take all privacy concerns seriously and will respond to all legitimate enquiries promptly and in good faith. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.