Privacy

Last Updated: 26/06/2025

This Privacy Policy (“Policy”) explains how Follwr, Inc. (“Follwr,” “we,” “us,” or “our”) collects, uses, shares, and safeguards information about individuals who visit or use www.follwr.app, our mobile applications, creator/fan tools, and any services that link to this Policy (collectively, the “Services”). “You” and “your” mean anyone who accesses or interacts with the Services.

By using the Services or communicating with us, you consent to the processing of your information in the United States as described here. If you do not agree, please do not use the Services.

This Policy does not cover:
(i) HR data about our employees/contractors/applicants (addressed in a separate HR privacy notice); or
(ii) identity checks operated directly by a third-party verification provider (e.g., Persona). That provider independently controls the data you submit to complete verification and will process it under its own terms and privacy policy.

 

1) What We Mean by “Personal Data”

“Personal Data” means information that identifies or can reasonably be linked to a person (alone or when combined). Examples include name, email, identifiers, device information, or user-generated content.

“Sensitive Personal Data” includes categories such as government IDs; financial account numbers; precise geolocation; credentials; health/biometric data; or similar data that could create heightened risks if misused.

We may create Aggregated/De-identified Data from Personal Data (e.g., removing identifiers and applying safeguards). Aggregated/De-identified Data is not subject to this Policy.

 

2) What We Collect

The information we collect depends on how you use the Services and your settings.

  • Contact & Account Data – name, email, phone, username, password, profile info.

  • Device/Network Data – IP address, device identifiers, OS/browser, language, settings, crash logs, and related telemetry.

  • Approximate Location – derived from IP or device settings (if enabled).

  • Content & Metadata – posts, images, audio/video, captions, comments, messages, timestamps, file metadata.

  • Usage & Interaction Data – pages/screens viewed, features used, links clicked, session timing, referring/exit pages, and creator–fan interactions (e.g., DMs, reactions, replies).

  • Payment/Payout Data – purchase history, price, currency, tax/billing info, and payout details for Creators (e.g., tax forms). Card data is handled by our payment processors—we do not store full card numbers.

  • Identity Verification Data (Creators) – information required to verify eligibility (e.g., government ID details, date of birth). You submit this directly to our verification provider; we may receive pass/fail signals, risk indicators, and limited data necessary to activate features. See Section 2.1 for Biometric details.

  • Social/Third-Party Data – if you connect a social account or use third-party sign-in, we may receive limited profile data the third party shares with us (subject to your settings there).

  • Marketing Preferences – opt-ins/outs, engagement with our emails or notifications.

  • Referrals – when you use “share” or “invite” features, we process the recipient info you provide to send the message (please obtain their permission first).

  • Other Data You Provide – surveys, support requests, or any info you choose to send us.

2.1) Biometric Data (Age/Identity Checks for Creators)

For age and identity verification, our third-party provider may capture and process Biometric Data (e.g., face geometry from a selfie and/or ID image) solely to verify eligibility, prevent fraud, and protect safety. Where applicable by law, we will obtain consent or rely on the provider to obtain it.

  • Deletion: Biometric Data controlled by Follwr (if any) is deleted when verification ends and is no longer needed for the original purpose (e.g., when you delete your account) or after a maximum retention period consistent with law and our operational needs. Data controlled by the verification provider is handled under that provider’s policy.

 

3) How We Use Personal Data

We use Personal Data to:

  1. Provide & Operate the Services – create/manage accounts; enable creator–fan interactions; host content; process purchases, tips, subscriptions, and payouts; provide support.

  2. Secure & Integrity-Protect – detect/prevent fraud, abuse, spam, and violations of policies; protect users and our platform; debug, monitor uptime, and ensure service quality.

  3. Improve & Innovate – analyze usage; test features; personalize experiences; develop new products; create de-identified analytics and insights.

  4. Communicate – send transactional messages (receipts, changes, security alerts) and, where permitted, marketing or product updates (you can opt-out; see Section 9).

  5. Comply with Law – tax reporting, sanctions/export controls, recordkeeping, and responding to lawful requests.

  6. With Consent/As Disclosed – for any other purpose you agree to at collection.

 

4) Cookies, Pixels & Similar Technologies

We and partners use cookies, SDKs, pixels, tags, local storage, and similar tools to:

  • Run the site/app (authentication, security, preferences).

  • Measure performance and understand feature usage.

  • Personalize content and (where applicable) show ads or recommendations.

You can manage preferences via our cookie banner/settings and your browser/device settings. Blocking some technologies may reduce functionality.

Session Replay/Diagnostics. We may use privacy-centric session replay or analytics technologies (e.g., PostHog or similar) to troubleshoot, improve UX, and monitor performance. These tools typically capture interactions (e.g., clicks, scrolls, navigation) and technical metadata, not your passwords or payment card numbers. We configure them to avoid collecting sensitive fields where possible.

Global Privacy Control (GPC). Where legally recognized, we treat a valid browser GPC signal as an opt-out of certain “sale”/“sharing” or targeted advertising.

 

5) When We Share Information

We do not sell Personal Data for money. We share information as follows:

  • Service Providers/Processors – cloud hosting, payments and payouts, identity verification, security, analytics, email/SMS, and customer support. These partners must use the data only to provide services for us and apply appropriate safeguards.

  • Other Users – what you choose to make public (profile, posts) is viewable by others according to your settings. Creator–fan interactions may involve limited data sharing necessary to deliver the feature.

  • Business Transfers – in a merger, acquisition, financing, reorganization, or sale of assets, data may be transferred to the successor (subject to this Policy).

  • Legal/Compliance – to comply with law, enforce our terms, respond to lawful requests, protect rights/safety, or prevent fraud/abuse.

  • With Your Direction/Consent – if you instruct us to or explicitly consent.

 

6) Your Choices

  • Cookies/Tracking: Use the cookie banner/settings and your browser/device controls (see Section 4).

  • Marketing Emails: Click Unsubscribe in any marketing email. We may still send essential transactional messages.

  • SMS/Push: Follow the instructions in the message or adjust device/app settings.

  • Permissions: You can withdraw app permissions (camera, photos, notifications) in your device settings—some features may no longer work.

 

7) Access, Correction, Deletion

You can review and update certain account details in your settings. You may also request access, correction, or deletion of Personal Data by emailing hello@follwr.app. We will respond consistent with applicable law. We may retain data as needed for legal obligations, dispute resolution, security, or backup.

 

8) Data Retention

We keep Personal Data only as long as necessary to operate the Services, comply with law, resolve disputes, protect our rights, and maintain business records. When no longer needed, we delete or de-identify data consistent with our retention schedules and legal requirements.

 

9) Security

We use administrative, technical, and physical safeguards designed to protect Personal Data (e.g., encryption in transit, access controls). No method is 100% secure, and we cannot guarantee absolute security. You are responsible for protecting your credentials and device.

 

10) Children

The Services are for individuals 18+ only. We do not knowingly collect Personal Data from anyone under 18. If you believe a minor provided data to us, contact hello@follwr.app and we will take appropriate steps.

 

11) International Data Transfers

We are headquartered in the United States and may process data there and in other countries where we or our providers operate. For transfers from the EU/EEA/UK/Switzerland, we rely on recognized mechanisms (e.g., Standard Contractual Clauses, adequacy decisions) and implement appropriate safeguards (see Addendum in Section 15).

 

12) Third-Party Sites & Services

Links or integrations (social sign-in, payment processors, verification providers, ad/analytics partners) are governed by those parties’ terms and privacy policies. We are not responsible for their practices.

 

13) Changes to This Policy

We may update this Policy from time to time. Material changes will be notified by posting on the Services or by reasonable means. Your continued use after the effective date means you accept the updated Policy.

 

14) Contact Us

Follwr, Inc.
1111b South Governors Ave STE 40285
Dover, DE 19904, US
hello@follwr.app
www.follwr.app

 

15) EU/EEA/UK/Swiss Addendum

Controller: Follwr, Inc. (contact in Section 14).
Purposes & Legal Bases: We process Personal Data for the purposes in Section 3 on the following legal bases:

  • Contract – to provide the Services you request (account, content hosting, payments).

  • Legitimate Interests – to secure and improve Services, prevent fraud/abuse, analyze usage, personalize non-intrusively, and support our business operations (balanced against your rights).

  • Consent – where required for cookies/targeting, certain marketing, or specific processing (you may withdraw consent at any time).

  • Legal Obligations – tax, accounting, sanctions/export, lawful requests.

  • Vital/Public Interest – where applicable.

Your Rights: subject to limits under applicable law, you may request access, rectification, erasure, restriction, portability, or object to processing based on legitimate interests or direct marketing. If processing relies on consent, you may withdraw it at any time.

  • Submit requests to hello@follwr.app.

  • You may lodge a complaint with your supervisory authority (e.g., ICO in the UK or your local DPA in the EU).

International Transfers: We use lawful transfer tools (e.g., SCCs) and supplementary measures where required. Details available on request.

 

16) U.S. State Privacy Addendum (including California, Texas, Nebraska)

This section supplements the Policy for residents of certain U.S. states and describes rights provided by state privacy laws. “Personal Information” here has the meaning under the applicable state law.

A) California (CCPA/CPRA)

Categories Collected: In the past 12 months, we may have collected the categories described in Section 2 (identifiers; account credentials; commercial data; device/network data; approximate location; audio/video content you choose to upload; professional info you include; inferences; and Sensitive Personal Information where you provide it or where needed for verification/payouts). We do not collect non-public education records.

Sources: You (directly), your devices, our processors/service providers, verification/payment partners, advertising/analytics partners, social networks you connect, and publicly available sources.

Business/Commercial Purposes: Providing, securing, improving the Services; analytics; processing transactions and payouts; compliance; and marketing consistent with Section 3.

Disclosures for Business Purposes: We may disclose Personal Information to service providers and other parties as described in Section 5.

“Sale”/“Sharing” (CPRA definitions): We do not sell Personal Information for money. Certain disclosures (e.g., to ad/analytics partners using cookies or similar tech) may be deemed a “sale” or “sharing” under California law. You can opt out via the cookie preferences and by sending a GPC signal supported by your browser.

Your California Rights:

  • Right to Know/Access & Portability (twice per 12 months)

  • Right to Delete

  • Right to Correct

  • Right to Opt-Out of Sale/Sharing (including via GPC)

  • Right to Limit Use of Sensitive Personal Information (where applicable; we use SPI only as reasonably necessary to provide the Services or for permitted security/compliance purposes)

  • Non-Discrimination

How to Exercise (CA):
Email hello@follwr.app or use available in-product tools. We will verify your request (we may ask for info like the email tied to your account). You may designate an authorized agent with proper authorization. We aim to respond within statutory timeframes.

B) Texas & Nebraska (and similar state laws)

Residents may have the rights to access, correct, delete, portability, and opt-out of: (i) targeted advertising, (ii) selling Personal Information (as defined under state law), and (iii) certain profiling that produces legal/similar significant effects.

How to Exercise (TX/NE): Email hello@follwr.app. If we decline a request, you may appeal by replying to our decision—appeals are resolved within the period required by law.

Opt-Out Signals: Where required, we honor recognized browser-based opt-out signals (e.g., GPC) for targeted advertising/sale/sharing.

 

17) Additional Notes

  • Do-Not-Track: Industry standards are evolving; we currently respond to opt-out signals as described above (e.g., GPC) rather than legacy DNT.

  • Financial Incentives: We do not offer programs that qualify as “financial incentives” for Personal Information under California law. If that changes, we will describe the terms and request opt-in consent.