GetBrovo Creator Program Privacy Notice

1.Who This Notice Applies To

This Creator Privacy Notice applies to:

• People who apply for or register a GetBrovo creator account
• Creators who participate in Creator Program campaigns or claim restaurant opportunities
• Creators who generate or share GetBrovo creator referral links
• Creators who submit content for review or receive commissions or payouts
• People who contact GetBrovo about the Creator Program

It also describes, at a general level, the information GetBrovo receives about customers who click a creator link, because that information is what makes attribution possible.

2.Creator Account and Profile Information

When you apply for or maintain a creator account, we may collect:

• Your name and any display name or creator name you use
• Email address
• Phone number
• Mailing address, city, state, and country where relevant to eligibility, tax, or payout requirements
• Date of birth or age confirmation where needed to confirm eligibility
• Account username and authentication information
• Profile photo or avatar if you choose to provide one
• Application answers, notes, and eligibility information

We use this information to create and administer your creator account, confirm eligibility, communicate with you, and operate the Creator Program.

3.Social Media Handles and Submitted Links

We collect the social media handles, profile links, and post links you provide or connect, along with related public information such as platform name, account handle, and the public URL of a submitted post.

Depending on the campaign, we may also record publicly available context about a submitted post, such as whether the post is public, whether it remains available, and its format.

We use this information to verify participation, display or embed your content where the Creator Program provides for it, review content against disclosed program requirements, and confirm that content remains available during a campaign period.

4.Restaurant and Campaign Participation

We collect information about your participation in the Creator Program, including:

• Restaurants and campaigns you view, claim, or participate in
• Opportunity status, claim time, and completion status
• Discounts or promotional meals applied through the platform
• Visit or order verification information connected to an opportunity
• Deadlines, submissions, and submission history

Participating restaurants may see information necessary for them to administer the opportunity, as described in the section titled "How We Share Information."

5.Creator Links, Clicks, and Attribution

When a creator link is generated for you, we create a record connecting that link to your creator account and to the applicable restaurant or campaign.

When a customer follows your creator link, we may process:

• The fact that a click occurred and the time it occurred
• The creator link identifier and the campaign or restaurant it belongs to
• A cookie or similar identifier set on the customer’s browser and device
• Referring page or source information
• Device type, browser type, operating system, and general technical information
• IP address, which may be used to infer general location for fraud prevention and regional rules
• Whether a qualifying order was later placed through the tracked path

The current attribution window is 30 days on the applicable browser and device. Attribution records are what allow a qualifying order to be connected to your link and to generate a commission.

For attribution purposes, GetBrovo receives order-level information such as order identifier, order amount, order status, and timing. GetBrovo does not provide creators with the customer’s name, phone number, email address, or delivery address.

6.Cookies and Similar Technologies

The Creator Program uses cookies and similar technologies, such as pixels, local storage, and link parameters, to:

• Recognize that a visit came from a creator link
• Maintain the attribution window described above
• Keep creators signed in and maintain session state
• Measure campaign performance and program analytics
• Detect and prevent fraud, self-referrals, and attribution manipulation
• Support platform security and troubleshooting

Customers and creators can control cookies through their browser settings. Blocking, clearing, or restricting cookies is permitted, and doing so may prevent attribution from being recorded, which means a commission may not be generated.

Where required by applicable law, GetBrovo will provide and honor an applicable consent or preference mechanism for non-essential cookies and tracking technologies.

7.Commission, Payout, and Payment Information

To calculate and pay commissions, we process:

• Qualifying order records attributed to your link
• Commission rate applied and commission amount calculated
• Weekly cycle period, cycle close date, and payout status
• Adjustments, reversals, refunds, chargebacks, and disputes affecting commissions
• Payout history, payout method, and payout timing
• Connected payment account identifiers assigned by the payment provider
• Payout failures, holds, and related status information

Payments are processed by a third-party payment provider such as Stripe. GetBrovo does not store your full raw bank account credentials or full raw card numbers.

The payment provider collects and processes information directly from you under its own terms and privacy policy, including the Stripe Connected Account Agreement and the Stripe Privacy Policy.

8.Identity Verification and Tax Information

Where required for payouts, compliance, or tax reporting, you or the payment provider may be asked to supply:

• Legal name and address
• Date of birth
• Taxpayer identification number, such as an SSN, ITIN, or EIN
• Form W-9 information for U.S. persons, or the applicable Form W-8 series information for non-U.S. persons
• Government-issued identification or other verification documents requested by the payment provider
• Business entity information where you are paid through an entity

Identity documents requested during payment-provider onboarding are generally submitted to and held by the payment provider rather than by GetBrovo.

We use this information to verify identity, meet legal and tax obligations, prevent fraud, and issue any tax forms required by applicable law.

9.Fraud, Security, and Enforcement Information

To protect the integrity of the Creator Program, we may process:

• Click, session, and order patterns used to detect self-referrals or attribution manipulation
• Duplicate account signals
• Device, browser, and IP information
• Records of suspected fake or artificially generated orders
• Investigation notes, findings, and outcomes
• Account status, restrictions, suspensions, and terminations
• Records of program-requirement violations and enforcement actions

We use this information to investigate suspected fraud or abuse, enforce these program rules, protect creators, restaurants, and customers, and comply with law.

10.Content Review and Moderation Information

When you submit content, we may process the submitted link or content reference, submission time, and the results of review against disclosed campaign, technical, legal, disclosure, and quality requirements.

We may keep records of review outcomes, correction requests, resubmissions, approvals, rejections, and the reason for a decision.

We use this information to administer campaigns, confirm eligibility for discounts and commissions, maintain program quality, and resolve disputes.

11.Communications and Support Records

We process communications you send to us and that we send to you, including:

• Support requests, tickets, and correspondence
• Email, SMS, and in-platform messages related to your creator account
• Campaign notices, payout notices, and program announcements
• Marketing communications about the Creator Program where you have provided any consent required by law
• Consent and opt-out records, including the date, time, and method of an opt-in or opt-out

Messaging may be delivered through third-party providers such as Twilio, which processes information under its own notice, including the Twilio Privacy Notice.

You may opt out of promotional messages at any time. Operational messages necessary to administer your account, campaigns, or payouts are not marketing messages and may continue.

12.Technical and Usage Information

When you use the creator dashboard or other GetBrovo properties, we may automatically collect IP address, device type, browser type, operating system, pages viewed, referring page, time and date of access, click activity, error logs, and similar technical information.

We use this information to operate, secure, troubleshoot, measure, and improve the Creator Program.

13.How We Use Information

We use Creator Program information to:

• Register, verify, and administer creator accounts
• Show available restaurants, campaigns, and opportunities
• Generate and manage creator links
• Record clicks and maintain the attribution window
• Attribute qualifying orders and calculate commissions
• Process payouts and manage payment-provider onboarding
• Handle refunds, chargebacks, reversals, and adjustments
• Review submitted content against disclosed program requirements
• Provide support and respond to your questions
• Send operational and, where permitted, promotional communications
• Detect, investigate, and prevent fraud, abuse, and attribution manipulation
• Maintain security and protect the platform and its users
• Produce analytics and reporting about program performance
• Meet legal, tax, accounting, and recordkeeping obligations
• Improve, develop, and maintain the Creator Program and the GetBrovo platform

14.How We Share Information

We may share Creator Program information with the following categories of recipients:

Participating restaurants

We share the information a restaurant needs to administer an opportunity, which may include your creator name or handle, the link to your submitted public post, opportunity and submission status, and aggregate performance connected to your campaign. We do not share your taxpayer identification number, payment credentials, or identity verification documents with restaurants.

Payment providers

We share the information required to onboard your connected account and process payouts, disputes, reversals, and tax reporting.

Hosting, cloud, and infrastructure providers

We share information with providers that host, store, back up, secure, and operate the platform.

Analytics and service providers

We share information with providers that help us measure program performance, troubleshoot, and improve the service.

Communications providers

We share contact information and message content with SMS and email providers so that messages can be delivered.

Professional advisers

We may share information with lawyers, accountants, auditors, and insurers where reasonably necessary and subject to confidentiality obligations.

Legal, safety, and compliance

We may share information where we reasonably believe it is necessary to comply with law, respond to lawful requests, enforce our terms, investigate fraud or security incidents, or protect the rights, property, or safety of creators, restaurants, customers, GetBrovo, or the public.

Business transfers

If GetBrovo is involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to applicable law.

We do not share your creator payout details, taxpayer identification number, or identity verification documents with other creators or with restaurants.

15.Selling and Sharing Under State Privacy Laws

GetBrovo does not sell creator personal information for money.

Several U.S. state privacy laws define "sell" and "share" broadly. Under some of those definitions, a "sale" can include disclosing personal information to a third party for valuable consideration even without a payment, and "sharing" can include disclosing personal information for cross-context behavioral advertising.

GetBrovo is reviewing the Creator Program’s data flows, cookies, analytics tools, and advertising vendors against those statutory definitions. Until that review is complete, this notice does not make a categorical statement that GetBrovo neither "sells" nor "shares" personal information as those terms are defined by every applicable state law.

When the review is complete, GetBrovo will update this notice with a specific statement and, where required by applicable law, will provide a clearly labeled mechanism to opt out of any sale or sharing and will honor recognized opt-out preference signals.

In the meantime, you may contact GetBrovo using the details in the "Contact Information" section with any question or request about how your information is used.

16.Your Privacy Rights

Depending on where you live, you may have rights regarding your personal information, which may include the right to:

• Know or access the categories and specific pieces of personal information we process
• Request correction of inaccurate personal information
• Request deletion of personal information, subject to exceptions
• Request a portable copy of certain information
• Opt out of the sale or sharing of personal information, and of targeted advertising, where applicable
• Limit the use of sensitive personal information, where applicable
• Opt out of certain profiling that produces legal or similarly significant effects, where applicable
• Appeal a decision we make about a privacy request, where applicable
• Not be discriminated or retaliated against for exercising a privacy right

To make a request, contact GetBrovo using the details in the "Contact Information" section. We will verify your request using information associated with your creator account and will respond within the time period required by applicable law.

An authorized agent may submit a request on your behalf where applicable law permits, subject to proof of authorization.

Some information cannot be deleted immediately where we are required or permitted to keep it, for example commission and payout records, tax records, fraud-prevention records, and records needed to resolve a dispute.

17.Data Retention

We keep Creator Program information for as long as reasonably necessary for the purposes described in this notice, including to:

• Administer your creator account while it is active
• Maintain attribution and commission records
• Support payouts, adjustments, reversals, chargebacks, and disputes
• Meet tax, accounting, and financial recordkeeping obligations
• Prevent and investigate fraud and abuse
• Enforce our terms and resolve disputes
• Comply with applicable legal obligations

Retention periods vary by record type. Financial, tax, and payout records are generally retained longer than operational records because law requires it. Click and attribution records are retained for the period needed to calculate, verify, audit, and resolve disputes about commissions.

When information is no longer needed, we take reasonable steps to delete it or to de-identify or aggregate it so that it no longer identifies you.

18.Security

We use reasonable technical, administrative, and organizational safeguards designed to protect Creator Program information, including access controls, encryption in transit, and restrictions on internal access.

No system is completely secure. We cannot guarantee that information will never be accessed, disclosed, altered, or destroyed as a result of a breach, error, unauthorized access, or third-party failure.

You should protect your creator account by keeping your credentials confidential, using a strong and unique password, protecting your email and phone accounts, and telling us promptly if you believe your account has been accessed without authorization.

19.Children’s Privacy

The Creator Program is not intended for children.

You must meet the minimum age required to participate, to enter into a binding agreement in your jurisdiction, and to hold an account on the social media platform where you publish.

We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will take reasonable steps to delete it.

If you believe a child has provided us with personal information, please contact us using the details in the "Contact Information" section.

20.Where Information Is Processed

The Creator Program is intended for use in the United States.

Information may be processed and stored in the United States and in other locations where GetBrovo or its service providers operate. Processing may occur across multiple U.S. states, and different state privacy laws may apply depending on where you live.

If you access the Creator Program from outside the United States, you understand that your information may be processed in the United States, where data protection rules may differ from those in your location.

21.Third-Party Platforms and Links

Creator content is published on third-party social media platforms that GetBrovo does not control. Those platforms collect and process information under their own privacy policies and terms.

The Creator Program may also link to or integrate with third-party services such as payment providers, analytics providers, and messaging providers.

This notice does not govern the practices of those third parties. We encourage you to review their privacy policies.

22.Changes to This Notice

GetBrovo may update this Creator Privacy Notice from time to time.

If we make changes, we may update the "Last Updated" date, post the updated notice, send an email, or show a notice in the creator dashboard.

Where required by applicable law, we will provide additional notice or obtain consent before a material change takes effect.

23.Contact Information

Questions, requests, or concerns about this Creator Privacy Notice may be sent to:

GetBrovo LLC

Mailing Address: 164 Davis Road, Westport, MA

Email: [email protected]

Website: growbrovo.com

Please include enough detail for us to understand and verify your request.