Privacy Policy

UGCStars is the controller of the personal information described in this policy, which means that we decide why and how it is processed, except where this policy says otherwise. Our details are: UGCStars LLC, company number [company number], registered office Eclipse Maslak İş Merkezi, E-Blok, Kat 5, Maslak, 34485 Sarıyer, İstanbul, Türkiye.

You can contact our privacy team at privacy@ugcstars.com, through our contact form, or by post at our registered office. We have not appointed a representative in the European Union or the United Kingdom.

This policy applies to the personal information of: (a) creators who apply to join, are listed on or have a profile on the Service, including profiles imported or created from publicly available information that have not yet been claimed; (b) creators we identify and invite to join through our sourcing process; (c) brands, agencies and their staff who search the Database, create an Account, purchase Annual Access or post a Brief; (d) members of the Affiliate Program; (e) people who nominate a creator, subscribe to our newsletter or contact us; and (f) visitors to our website.

This policy does not apply to websites, platforms or services operated by third parties, including the social media platforms that host creators’ work, which have their own privacy policies. It also does not apply to the way a brand uses a creator’s information after the brand has obtained it through the Service. Each brand is responsible for its own use of that information, as explained in Section 14.

If you use the Service on behalf of an organization, such as a brand or agency, that organization may have its own privacy policy that applies to the information it holds about you.

When you apply to join UGCStars, we ask for the following information, some of which is required and some optional: (a) identity and contact details, being your first and last name and your email address; (b) location, being your country and, if you choose, your state or city; (c) your birth year and gender; (d) the languages you create content in; (e) your usernames or profile links on TikTok, Instagram, X and YouTube and, if you choose, a follower range for each; (f) your interests and the types of content you make, such as product reviews, unboxing, testimonials, tutorials, product demos, vlogs, photography and voiceovers; (g) the details brands search for, being your skin type, whether you have pets and which kind, whether you have children and how many, and, if you choose, that you are expecting a child, with an expected month and year; (h) your starting rate per video and its currency; (i) if you choose, a portfolio link, up to six links to sample work on TikTok, Instagram Reels or YouTube Shorts, a short description of yourself and a profile photo; and (j) your choices about publication and email, including your agreement to this policy and to publication of your profile after review, and whether you want to receive opportunity emails and our newsletter.

After you join, we collect the information you add or change in your account, the Casting Calls you apply to, any message you include with an application, your settings, such as whether your profile is listed or hidden, and your communications with us.

If you claim an existing profile, we collect the information needed to confirm that the profile is yours, such as the code we send to the email address on the profile or the code you add to the bio of a linked social account, and the date and time of verification.

We use your birth year to confirm that you are at least eighteen and to show an age range that brands can search by. We use the rest of your information to build your profile, to make it searchable, to match you with Casting Calls and to show brands what they need to decide whether to contact you.

Some details you may choose to provide can reveal information that the law treats as sensitive. In particular, telling us that you are expecting a child, and the expected month and year, is information about your health, and some jurisdictions may treat skin type as health-related. Age and gender are protected characteristics under anti-discrimination laws in many jurisdictions.

We process the fact that you are expecting a child, and the expected month and year, only on the basis of your explicit consent, which you give by selecting that option and adding the dates. We use this information only to show the attribute on your profile and in search filters, to match you with relevant opportunities and to remind you to update your profile after the expected date. After the expected month, we email you once to ask whether your baby has arrived. If you tell us, your profile shows you as a parent instead, and we keep whether you had a boy, a girl or twins and the month of birth, which we never show publicly. If you would rather not say, or do not answer within 30 days, we remove the attribute. We never show the expected date publicly. You can remove the information at any time from your account, which withdraws your consent for the future.

Where the law treats skin type as sensitive, we process it on the basis of your explicit consent, given when you select it, and you can change or remove it at any time.

We do not ask for, and you should not provide, information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, sex life or sexual orientation, or criminal convictions, and we do not use the information you give us to infer any of those characteristics.

We do not use sensitive information for advertising, and we do not include it in any information we share with payment processors, card networks or banks in connection with a payment dispute.

If you create an Account or purchase Annual Access, we collect your email address, your full name and, if you choose, your company name for the invoice, together with any change you ask us to make to your login email.

When you purchase, we collect the details of your Order, including the amount, currency, date and time, any promotional or affiliate code used, the version of our Terms of Service you accepted and the time you accepted it. Your payment card details are collected directly by our payment processor, Stripe. We do not receive or store your full card number. We receive limited information from the processor, such as the card brand, the last four digits, the expiry date, the billing country and postal code, a transaction identifier, the outcome of fraud checks and notice of any refund or dispute.

When you use the Service, we collect the creators you save, the shortlists you create, the searches you save, your search alert and email preferences, the templates you download, and records of the creator profiles you open while contact details are displayed and of contact actions such as copying an email address or opening an email link.

If we ask you to verify your identity, payment method or organization under our Terms of Service, we collect the information you provide for that purpose.

When you post a Brief, we collect the brand name and website, your name and email address, the campaign name, the product and its description, the content types and deliverables you need, the countries and languages you are targeting, any criteria for creators that you specify, such as age range, gender, niches or attributes, and the type of compensation offered. We may publish the Brief as a Casting Call, send it to matching creators and share your contact details with creators, as described in Sections 12 and 13.

When a creator applies to a Casting Call, we collect the application and any message, and share them with the brand that posted the Brief, together with the creator’s profile.

When you nominate a creator, we collect the creator’s social profile link and, if you provide them, the creator’s name, the creator’s email address, which you should provide only if the creator shared it with you, and your name. We use this information to decide whether to invite the creator, and we may tell the creator that they were nominated and, if you gave it, your name.

If you apply to the Affiliate Program, we collect your name, email address, country, the channels you plan to use to promote UGCStars, your approximate audience size, your chosen referral code, the PayPal email address to which payouts should be sent, and your acceptance of the Affiliate Terms and of our disclosure requirements.

Before your first payout, we collect a tax form, such as an IRS Form W-9 or W-8BEN, which may include your taxpayer identification number, address and country of tax residence. We use it only to comply with tax law and to make payouts.

We record clicks on your referral link, purchases attributed to you, commissions, holds, reversals and payouts. So that you can check your commissions, we show you a masked form of each referred customer’s email address, such as its first letter and email domain, together with the purchase date, amount and status. We do not show affiliates the names, full email addresses or payment details of referred customers.

When you visit or use the Service, we and our service providers collect: (a) device and connection information, such as your IP address and the approximate location derived from it, browser type and version, operating system, device type, language settings and time zone; (b) usage information, such as the pages you view, the links you click, the searches and filters you use, the date and time of each request, the page that referred you, and any referral or campaign parameters in the link you followed, such as an affiliate code; (c) account and security events, such as requests for and uses of login links, failed attempts, changes to account details, and the IP address and device associated with each; and (d) records of access to paid features, as described in Section 5.3.

We use cookies, local storage and similar technologies to collect some of this information. Our Cookie Policy explains which ones we use and how you can control them.

When we send emails, our email provider records whether each email was delivered, bounced or reported as spam, and whether the recipient unsubscribed. Where this is enabled, it may also record whether an email was opened or a link in it was clicked.

To grow the Database, we look for working user-generated content creators in public sources and invite them to join. This process combines automated tools and human review. We search publicly available posts and profiles on social media platforms, such as replies by creators to public posts from brands looking for UGC creators, using the X API and research tools from third-party providers, such as xAI’s Grok and OpenAI’s ChatGPT agent. We may also receive lists of creators through manual imports and nominations.

From these sources, we collect only the information needed to identify the creator and send a single invitation: the creator’s name or display name, social handle and public profile link, the public post in which we found them, any public website, and a business email address that the creator has published for professional contact, for example in a social media bio, on their website or on a professional profile, together with a note of where we found it.

Before we send an invitation, we check whether the person is already in our records, whether they have previously asked us not to contact them, and how confident we are that the email address is a public business address belonging to the creator. An invitation is sent automatically only when those checks give a high level of confidence; otherwise, a member of our team reviews the record, or no invitation is sent. We send each creator at most one invitation, every invitation includes a link to opt out, and we keep a permanent record of opt-outs so that we never contact that person again unless they choose to join.

If we never contact a person we found through sourcing, we delete their record after sixty (60) days. If you received an invitation and do not want to hear from us, you can opt out using the link in the email or by contacting us, and you can ask us to delete the information we hold about you, apart from the suppression record described above.

Some creator profiles were created from records held on a previous version of the UGCStars website, including creator records kept in spreadsheet and database tools before the current Service. Customers who purchased lifetime access on a previous version are recognized by the email address they used for that purchase.

We also receive information from our payment processor, such as payment status, fraud signals and notices of refunds and disputes; from affiliates, through the referral links and codes used to reach us; from email providers, such as delivery and complaint notices; and, where you interact with us on social media, from those platforms.

We use personal information only where we have a lawful reason to do so. If you are in the United Kingdom, the European Economic Area or Switzerland, the law requires us to identify a legal basis for each use. We rely on: (a) performance of a contract, where we need the information to provide the Service you asked for, or to take steps you asked for before entering into a contract; (b) legitimate interests, where we or a third party have a legitimate interest in using the information that is not overridden by your interests, rights and freedoms; (c) consent, where you have given us permission, which you can withdraw at any time without affecting processing that took place before you withdrew it; and (d) legal obligation, where we need the information to comply with the law.

The table below summarizes our main purposes, the information we use for each, and the legal basis we rely on.

Where we rely on legitimate interests, we have balanced our interests against yours, taking into account the nature of the information, your reasonable expectations and the safeguards we apply, such as limiting sourcing to public business contact details, sending a single invitation and honoring opt-outs permanently. You can ask us for more information about this balancing, and you have the right to object, as explained in Section 21.

We also create aggregated and de-identified information, such as the database statistics and the UGC rate index, by combining information about many creators, including niches, countries, languages, content types and starting rates. This information does not identify any individual, and we may use and publish it for any purpose.

If we want to use personal information for a new purpose that is not compatible with the purposes described in this policy, we will tell you before we do so and, where the law requires, ask for your consent.

We use automated processing to organize creator profiles. We place profiles in search results, sort them by relevance and other ranking factors, and match profiles to Casting Calls using the niches, countries, languages, attributes and other criteria a brand has chosen. Ranking factors may include how complete a profile is, how many sample works we have verified, recent activity and relevance to the search.

In our sourcing process, automated checks estimate whether an email address is a public business address belonging to a creator, and decide whether an invitation can be sent automatically or must first be reviewed by a person.

Decisions to approve, decline, suspend or remove a creator profile are made by members of our team, who may use automated checks, such as checks for broken links, invalid social links, missing information or email delivery failures, to help them. We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.

Once we approve a creator profile, and for as long as it is listed, anyone using the Service can see the information on the profile that we make publicly available. This may include your name as shown on the profile, usually your first name and the initial of your last name, your profile photo, country and, if you gave it, your state or city, an age range calculated from your birth year, your gender, languages, interests, content types, attributes, follower ranges, starting rate and description. We do not display your birth year itself. Public profile pages and niche and country pages may be indexed by search engines.

Your business email address, social profile links and sample works are shown only to logged-in holders of Annual Access, and only as your settings permit.

We never show the expected month and year you give when you tell us you are expecting a child. Brands can see and filter by the attribute itself.

When you hide your profile, it no longer appears in search, brands cannot open it, and you do not receive opportunity emails. When you delete your profile, we remove it from the Service. Search engines and other third parties that have copied public pages may take some time to update their records, and we do not control their copies.

A brand that posts a Brief can see the profiles and messages of creators who apply. Creators who receive or view a Casting Call can see the Brief and any brand contact details included in it.

We share personal information only as described in this policy. We share it: (a) with brands, as described in Section 12, because creators ask us to when they list a profile; (b) with creators, where a brand posts a Brief, as described in Sections 6 and 12; (c) with service providers that process information on our behalf and on our instructions, including providers of hosting, databases and storage, email delivery, payment processing, analytics, customer support, security and fraud prevention, and the research and artificial intelligence tools used in sourcing, under contracts that require them to protect the information and to use it only to provide services to us; (d) with our payment processor, card networks, issuing banks and other payment service providers, to process payments and refunds, to prevent fraud and to respond to payment disputes, as described in Section 15; (e) with affiliates, in the limited and masked form described in Section 7.3, where a purchase is attributed to them; (f) with our professional advisers, such as lawyers, accountants, auditors and insurers, where necessary; (g) with courts, law enforcement agencies, regulators, tax authorities and other public authorities, where we believe in good faith that disclosure is required by law, or is necessary to protect the rights, property or safety of UGCStars, our users or others, to detect or prevent fraud, or to enforce our Terms of Service; (h) with a buyer, investor, successor or other party in connection with a merger, acquisition, financing, reorganization, sale of assets or similar transaction, or in insolvency, subject to appropriate confidentiality protections; and (i) with anyone else, with your consent or at your direction.

We do not sell personal information to data brokers, and we do not share personal information for cross-context behavioral advertising. Brands pay for access to the Service, including creators’ contact details, because creators choose to be listed so that brands can find and contact them. A creator can stop this disclosure at any time by hiding or deleting their profile.

When a brand views or copies a creator’s contact details or other information through the Service, the brand decides how it uses that information and becomes responsible for it as an independent controller, or as a business under US state privacy laws. Our Terms of Service allow brands to use creator information only to contact creators individually about genuine collaborations, require them to comply with privacy and anti-spam laws, and prohibit bulk marketing, resale and other misuse.

We cannot recall information a brand has already seen. If you are a creator and a brand contacts you in a way you did not expect, you can ask the brand directly to stop contacting you and to delete your information, and you can report the brand to us. We investigate reports and may suspend or terminate a brand’s access.

We use personal information to protect UGCStars, our customers and our creators from fraud and payment abuse. This includes screening Orders, detecting unusual account activity, enforcing usage limits, and responding to refund requests and payment disputes.

If a payment is disputed or charged back, we may give our payment processor, the relevant card network and the cardholder’s issuing bank the information reasonably necessary to show that the payment was authorized and that Annual Access was described accurately and delivered. This may include the Order record and receipt; the description of Annual Access shown at checkout; the record of acceptance of our Terms of Service; the IP address, approximate location and device information associated with the purchase and with later logins; the dates and times of requests for and uses of login links; records of the paid features used, such as the number of creator profiles opened while contact details were displayed and the dates on which they were opened; and our correspondence with the customer.

We rely on our legitimate interests in preventing fraud and in establishing, exercising and defending legal claims. We limit dispute submissions to what is necessary, we never include creators’ sensitive information, and we identify individual creators whose profiles were opened only where that is necessary to show that the Service was used.

Our payment processor may use information about Orders, payment methods and disputes in its own fraud prevention systems, as an independent controller and in accordance with its own privacy policy. We may also refuse further Orders from people, email addresses, email domains, payment methods or devices associated with fraud, or with chargebacks made in breach of our Terms of Service.

We are based in Türkiye and our service providers are located in several countries, including the United States. Your information may therefore be transferred to, stored in and processed in countries other than the one in which you live, which may have data protection laws different from those in your country.

Where we transfer personal information from the United Kingdom, the European Economic Area or Switzerland to a country that has not been recognized as providing an adequate level of protection, we use appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum or, where the recipient is certified, the EU-U.S. Data Privacy Framework and its UK and Swiss extensions. You can ask us for a copy of the relevant safeguards.

We keep personal information only for as long as we need it for the purposes described in this policy, including to provide the Service, to comply with legal, tax and accounting obligations, to resolve disputes, to prevent fraud and to enforce our agreements. The table below sets out our main retention periods.

When a retention period ends, we delete the information or anonymize it irreversibly. Information held in backups is deleted when those backups are overwritten. We may keep information for longer where the law requires it, or where it is needed for an ongoing investigation, dispute or legal claim, until that matter is resolved.

We use technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse and alteration. These include encryption of data in transit, passwordless login through time-limited one-time links, role-based access controls that limit our staff and contractors to the information they need for their role, logging of administrative access, and due diligence on our service providers.

No method of transmission or storage is completely secure, and we cannot guarantee the security of information. Because access to your email account gives access to your UGCStars Account, you are responsible for keeping your email account secure. If we become aware of a personal data breach that affects you, we will notify you and the relevant authorities where the law requires.

Creators can edit every detail of their profile, switch it between listed and hidden, and delete their profile and data permanently from their account. They can also choose whether to receive opportunity emails and our newsletter.

Brands and customers can manage optional emails, such as saved search alerts and product updates, from their Account. Login links, receipts and other account emails are required while the Account exists.

Anyone can unsubscribe from marketing emails using the link in each email, manage cookies as described in our Cookie Policy, and opt out of sourcing invitations using the link in the invitation or by contacting us.

We send several kinds of email and keep them separate: (a) account and transactional emails, such as login links, email verification, receipts, application decisions, requests to update a profile and security notices, which are necessary to provide the Service; (b) opportunity emails to creators about matching Casting Calls, which we send only if the creator opts in; (c) saved search alerts and product updates to brands, which can be switched off; (d) newsletters, which we send only to people who subscribe or, where the law permits, to existing customers, with an opt-out in every email; and (e) single invitations to creators identified through sourcing, as described in Section 9.

We keep a suppression list of email addresses that have unsubscribed, opted out, bounced permanently or reported our emails as spam. Addresses on that list do not receive marketing or invitation emails unless the person later chooses to join or subscribe.

Depending on where you live, you may have some or all of the following rights in relation to your personal information: (a) to be informed about how we use it, which is the purpose of this policy; (b) to access it and receive a copy; (c) to have inaccurate or incomplete information corrected; (d) to have it deleted; (e) to restrict our use of it; (f) to receive it in a structured, commonly used and machine-readable format, and to have it transmitted to another organization; (g) to object to our use of it where we rely on legitimate interests, and to object at any time to its use for direct marketing; (h) to withdraw your consent at any time, where we rely on consent; and (i) not to be subject to decisions based solely on automated processing that significantly affect you.

Creators can exercise most of these rights directly from their account. To exercise any right, contact us at privacy@ugcstars.com or through our contact form. We will ask you to verify your identity, usually by confirming that you control the email address associated with the information or, for a social handle, by a method such as replying from the business email address we hold or adding a code to the account’s bio. If you make a request through an authorized agent, we may ask for proof of the agent’s authority and verify your identity directly with you.

We will respond within one month of receiving a verified request, or within any other period required by the law that applies to you. Where the law allows, we may extend that period, for example for complex or numerous requests, and we will tell you if we do. We do not charge a fee unless a request is manifestly unfounded or excessive.

Some rights are subject to limits. For example, we may keep information we need to comply with a legal obligation, to establish, exercise or defend legal claims, including payment disputes, or to honor an opt-out. If we cannot fully comply with a request, we will tell you why.

If you are in the United Kingdom, the European Economic Area or Switzerland, you have the right to lodge a complaint with a data protection supervisory authority, in particular in the country where you live or work or where an alleged infringement took place. In the United Kingdom, this is the Information Commissioner’s Office. We would appreciate the chance to address your concerns before you approach a supervisory authority.

This section supplements the rest of this policy for residents of California and of other US states with comprehensive privacy laws, such as Colorado, Connecticut, Virginia, Utah, Texas and Oregon. It uses the categories of personal information described in the California Consumer Privacy Act, as amended (the “CCPA”).

In the last twelve (12) months we have collected the following categories of personal information, from the sources and for the purposes described in Sections 3 to 11: (a) identifiers, such as name, email address, social handles, IP address and account identifiers; (b) customer records, such as name, email address and limited payment information; (c) characteristics of protected classifications under California or federal law, such as age, derived from birth year, gender and pregnancy status, where a creator chooses to provide them; (d) commercial information, such as Orders and purchase history; (e) internet or other electronic network activity, such as browsing, search and interaction information on the Service; (f) approximate geolocation derived from IP address, and the country and city a creator provides; (g) audio, electronic and visual information, such as profile photos and sample works; (h) professional information, such as rates, portfolios and work samples and, for brands, company name; (i) inferences drawn from the above, such as profile attributes used to match creators with opportunities; and (j) sensitive personal information, being pregnancy information that a creator chooses to provide and, for affiliates, taxpayer identification numbers collected on tax forms.

We disclose each of these categories for business purposes to the categories of recipients described in Section 13. We use sensitive personal information only for the purposes the CCPA permits, such as providing the services you request and complying with legal obligations, and not to infer characteristics about you.

We do not sell personal information and do not share it for cross-context behavioral advertising, as those terms are defined in the CCPA, and we have not done so in the last twelve (12) months. Creator profile information is disclosed to brands at the creator’s direction, which is not a sale. We do not knowingly sell or share the personal information of consumers under sixteen (16) years of age.

Subject to applicable exceptions, you have the right to: (a) know what personal information we have collected about you, including the categories of information and sources, the purposes and the categories of third parties to whom we disclose it, and obtain a copy of the specific pieces of information; (b) delete personal information we collected from you; (c) correct inaccurate personal information; (d) opt out of any sale, sharing or targeted advertising, which we do not carry out; and (e) not receive discriminatory treatment for exercising your rights. Residents of some states can also appeal our decision on a request by replying to our decision or by emailing privacy@ugcstars.com with the subject line “Appeal”. If we deny your appeal, you may contact the attorney general of your state.

We treat a Global Privacy Control signal from your browser as a valid request to opt out of any sale or sharing of personal information associated with that browser.

We will respond to verified requests within forty-five (45) days, and we may extend that period by a further forty-five (45) days where reasonably necessary, in which case we will tell you. The retention period for each category of information is described in Section 17.

California residents may also ask us, once a year, for information about any disclosure of personal information to third parties for their own direct marketing purposes under California Civil Code Section 1798.83. We do not make such disclosures.

The Service is intended only for people aged eighteen (18) or over. We do not knowingly collect personal information from anyone under eighteen. If we learn that we have collected personal information from someone under eighteen, we will delete it and close any related profile or Account. If you believe that a child has provided us with information, please contact us.

Creators may tell us whether they have children and how many, so that brands can find parent creators. We do not ask for, and creators must not include in their profile, the names, photos or other details of their children. Creators are responsible for obtaining any consent required by law, and by the platforms they use, before featuring a child in their own content.

We may update this policy from time to time. We will publish the updated version on the Service with a new “Last updated” date and, if the changes are material, we will tell you by email or by a notice on the Service before they take effect. Where the law requires your consent to a change, we will ask for it.

If you have questions about this policy or about how we handle personal information, or if you want to exercise your rights or make a complaint, contact our privacy team at privacy@ugcstars.com or write to us at Eclipse Maslak İş Merkezi, E-Blok, Kat 5, Maslak, 34485 Sarıyer, İstanbul, Türkiye. We aim to respond to every inquiry promptly.