Privacy Policy

Last updated: 21 September 2026 · Version 1.5

1. Who is responsible for your data

The data controller is Dmytro Korniienko, autónomo, NIF ESZ5245422R, Avinguda del País Valencià 7, 46117 Bétera, Valencia, Spain, trading as Promo App. Contact for any privacy matter, including requests to exercise your rights:

• Email: notification@marketingbotapp.com

This policy explains how personal data is processed when you use Promo App: the creator app at promoapp.marketing, the marketplace for clients at artistpromoapp.marketing, the Promo App apps for iOS and Android, and the connected Telegram and Discord bots (together, the “Service”). It is written to meet Regulation (EU) 2016/679 (the “GDPR”). The rules of using the Service are in the Promo App Rules.

2. What data we collect

Data	Why we need it	Legal basis
Email address	To create your account, sign you in with a one-time code, and send the service (transactional) email you agree to at sign-up: request verdicts, payment and payout notices, deadlines and reminders, support replies, account, security and rules updates. Optional campaign and offer email is sent only while you leave it enabled and can be turned off at any time in Settings → Notifications or via the unsubscribe link.	Performance of a contract (Art. 6(1)(b)); consent (Art. 6(1)(a)) for optional campaign and offer email, withdrawable at any time
Display name	Shown to managers and in the community chat.	Performance of a contract
Creator profile: account links and handles, profile picture, description, topic, price per video, Bulk Deals	To verify that you own the accounts you post from and to show your profile to the customers who review your requests. This is the service itself (Promo App Rules, 1.5).	Performance of a contract
Public data of your accounts: followers, views, links to public videos	To show customers what your accounts already show publicly and to build campaign reports.	Performance of a contract
Date of birth (creators who joined after 15 September 2026)	To apply the age rules: from 13 to 17 with a parent's agreement, full access from 18.	Performance of a contract; legal obligation (Art. 6(1)(c))
Parental consent forms sent before 21 September 2026 by creators aged 13 to 15: the signed form, the parent's name, relationship, email and phone, and a bank statement or screenshot. We no longer ask for them.	Kept as the record of that consent. Seen only by the managers. No identity documents are requested.	Legal obligation (Art. 6(1)(c)); consent of the parent (Art. 8)
Payout details (PayPal address, USDT wallet, card or bank account)	To pay you. Visible only to you and to the one who sends you money: a Promo App manager or the manager who runs the campaign. Never shown to clients, labels, artists or AI providers.	Performance of a contract
Creator tax profile: legal name, date of birth, country of tax residence, address, tax number of your country if you have one, EU VAT number of a business, and the name of the holder of your payout account. You can change any of them in the app.	To issue an invoice in your name for every payout (self-billing, Rules 2.3), to keep the accounting records of those payouts, and to report creators to the tax authority under the EU platform reporting rules (DAC7). The details are seen only by the manager who pays you and by our accountant. Clients and other creators never see them.	Performance of a contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c))
Invoices issued in your name and the payment receipt attached to each of them	To document each payout. You see them in Payments and accept each one.	Performance of a contract; legal obligation (Art. 6(1)(c))
Client data: name or company, billing address, country, VAT number, invoices, top-ups and payments	To issue invoices, apply the right tax and keep payment records.	Performance of a contract; legal obligation (Art. 6(1)(c))
Client friends: nickname, friends list, friend requests, blocked clients, people you hid from suggestions, and messages between friends	To let clients add each other, suggest friends of friends (you can turn this off in Friends → Settings) and deliver messages. Friends see your nickname and approved company name. The Promo App team can see messages between friends to prevent work outside the platform and to handle reports.	Performance of a contract; legitimate interest in preventing abuse (Art. 6(1)(f))
Pictures you attach to a chat message (for example, a payment receipt)	To show them to the manager you are writing to.	Performance of a contract
Links to the videos you publish	To confirm the work was delivered, to release payment and to show the result to the customer of the campaign.	Performance of a contract
Messages you send in chat or support	To answer you and to keep a record of the conversation.	Performance of a contract; legitimate interest in support quality (Art. 6(1)(f))
Telegram or Discord identifier, if you use those bots	To link your account across platforms and to send you notifications.	Performance of a contract
Push notification token, if you use the Promo App app for iOS or Android	To deliver notifications to your phone. Kept while the app is installed; removed when you delete your profile, and it stops working once you delete the app.	Performance of a contract
Technical logs (IP address, browser type, time of request)	Security, abuse prevention, detecting work outside the platform and troubleshooting. Kept for a short period.	Legitimate interest (Art. 6(1)(f))

We do not knowingly collect special categories of data (health, political opinions, biometrics and similar). Do not send such data to us.

3. Who receives your data

A creator's profile and public data (row “Creator profile” and “Public data” above) are shown to:

• The customer of the campaign and its managers: Promo App, a marketplace client, an independent manager or the VOID partner, depending on who the campaign card names.
• The label or the VOID partner, through the campaign form a manager fills in.
• The artist, through a campaign report link the client shares.
• Any visitor of the site, on the top creators board and the public creator page.

The manager's rating, order history, refunds, bans, email, Telegram, Discord and support messages stay inside Promo App.

Some third parties we rely on to deliver the Service process limited data:

• Payment providers (PayPal, Stripe, banks and crypto networks), to send payouts and receive top-ups.
• Email delivery, to send your one-time sign-in codes and notifications.
• Telegram and Discord, only if you choose to use those platforms; their own privacy policies then apply to what happens inside their apps.
• AI providers (OpenAI, Google), to draft support answers, write the account description for a campaign form and translate texts. They never receive payout details. Where a provider is located outside the EEA, the transfer relies on the European Commission’s Standard Contractual Clauses.
• Tax authorities, when the law requires us to report.

4. Where your data is stored

All personal data is stored on servers located in the European Union, in the Netherlands. Backups are kept on the same infrastructure. Data is not transferred outside the European Economic Area for storage.

5. How long we keep it

• Account data. While your account exists, and up to 12 months after you ask us to delete it, only where we must keep records of completed payments.
• Parental consent documents. While the account exists and 12 months after it is deleted.
• Payment records, invoices and tax details. For as long as required by applicable accounting and tax law.
• Support conversations. Up to 24 months.
• Technical logs. Up to 90 days.
• One-time sign-in codes. 15 minutes, then they expire and become unusable.

6. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased (“right to be forgotten”);
• restrict or object to processing;
• receive your data in a portable, machine-readable format;
• withdraw consent at any time, where processing is based on consent;
• lodge a complaint with a supervisory authority in your country of residence.

Showing a creator's profile to customers is part of the service and cannot be switched off while the account exists. To stop it, delete the account.

Write to notification@marketingbotapp.com and we will respond within 30 days.

You can delete your account yourself at any time, without writing to us: in the app or on the website open Settings and tap Delete profile. What is removed and what is kept is described on the Delete your account page.

7. Security

The Service is served exclusively over HTTPS with a valid TLS certificate. Sign-in uses one-time codes sent to your email, so there are no passwords to steal. Session cookies are marked Secure and HttpOnly, so they are never sent over an unencrypted connection and cannot be read by scripts. The site sets a strict Content Security Policy and other protective HTTP headers. Access to the database is limited to the operator.

No system is perfectly secure. If you believe your account has been compromised, contact us immediately.

8. Cookies

We use only strictly necessary cookies. See the Cookie Policy. There are no advertising or analytics trackers on this site.

9. Children

Creators must be at least 13. A creator aged 13 to 17 needs a parent's or legal guardian's agreement, confirmed with a checkbox in the app. Clients must be at least 18. If we learn that an account belongs to someone younger than allowed, we close it.

10. Changes

If this policy changes materially, we will show a notice in the app before the change takes effect. The version and date at the top always identify the current text.

11. Governing law and disputes

This policy is governed by Spanish law, without prejudice to the mandatory consumer protection rules of your country of residence. Any dispute shall be submitted to the competent courts of the city of Valencia, Spain.