Draft. Pending legal review.
Creator Program Privacy Notice
Version 1.0 (draft)
Effective date to be set after legal review
This notice explains how Inkitt GmbH (“Galatea,” “we,” “us,” or “our”) processes personal data for the Galatea Creators program (the “Program”). Inkitt GmbH is located at Saarbrücker Str. 36, 10405 Berlin, Germany. This notice supplements the Galatea Privacy Policy. If the documents conflict on a Program-specific issue, this notice controls.
1. Data we collect
We may collect:
- your name and contact email;
- the social accounts you post from, and, when we can match it by email, your Galatea app account identifier so rewards can reach the correct account;
- attribution such as the link or campaign that brought you to the Program site;
- public post URLs, registration information, and your confirmation that a post carries the required disclosure;
- public post content and publicly visible information such as view counts, tags, captions, publication status, and engagement;
- Program review decisions, view snapshots, credit calculations, balances, redemptions and reward history, suspected fraud or policy issues, and support communications; and
- email delivery and bounce information when our email provider makes it available; and
- with your consent, approximate location, device and browser information, pages viewed, and selected site-link clicks.
We collect this information from you, from public social platforms, from Galatea account systems, and from service providers that help operate the Program.
2. How and why we use the data
We process Program data:
- to register you, receive and review submitted posts, administer your participation, connect your contact email to the correct Galatea account, calculate credits, fulfill rewards, and send operational messages necessary to provide the Program;
- for our legitimate interests in verifying eligibility and organic views, measuring and improving the Program, preventing fraud and abuse, protecting rights, and maintaining security;
- to comply with legal obligations and respond to lawful requests; and
- with consent where applicable law requires it, including for uses that are optional rather than necessary to operate the Program.
We may also use creator posts as permitted by the Galatea Creators Program Terms & Content Guidelines. We do not use the Program contact email for unrelated marketing unless you have separately permitted that use. Registration, submission, reward, and Program-status messages are operational communications. Program decisions are not made solely through automated decision-making.
3. How we share the data
We may share Program data with:
- Inkitt GmbH affiliates and team members who operate, review, support, secure, or evaluate the Program;
- service providers such as Supabase for form submissions and operational records; Google Workspace for files; Google Analytics for website measurement; an email provider for Program email; reward fulfillment partners such as the Galatea Shop; and Galatea systems for account matching and reward delivery;
- professional advisers, auditors, rights holders, and contractors when reasonably necessary; and
- authorities or other parties when required by law or needed to protect rights, safety, security, or the Program.
Public social posts remain subject to the social platform's privacy practices. Galatea uses a post outside Program administration only with your separate permission, as described in the Program Terms.
We do not sell Program registration data. International transfers and safeguards are described in the Galatea Privacy Policy.
4. Website analytics
We use website analytics to understand approximate geography, device and browser types, pages viewed, and selected link clicks so we can improve the site. Advertising signals and ad personalization are disabled. We do not send registration or submission responses, Galatea account details, contact information, or public post links to Google Analytics.
5. Retention
We generally retain registration, submission, review, and reward records for up to three years after the creator's last participation. We may retain records longer when reasonably necessary for legal claims, fraud prevention, rights management, accounting, or audit obligations. Public posts may also remain available through the social platform after Program records are deleted.
6. Your choices and rights
You may stop participating at any time by no longer submitting posts and contacting us. Depending on where you live, you may have rights to access, correct, delete, restrict, object to, or receive a copy of personal data, or to withdraw consent where processing relies on consent. These rights may be subject to applicable legal exceptions.
To exercise privacy rights or contact the Data Protection Officer, use the contact information in the Galatea Privacy Policy. Program questions may be sent to creators@galatea.com.
7. Age and changes
The Program is limited to people age 18 or older. We may update this notice when the Program or our processing changes. We will publish the updated notice with a new effective date and provide additional notice when required by law.