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Privacy Policy

Effective Date: April 2025

Splay technologies private limited (“Splayed.ai”, “we” or “us”) is an Indian company offering SaaS services at its influencer marketing ad platform found at splayed.ai (the “Platform”). The Platform provides services for brands, agencies and creators to discover influencers, manage campaigns, analyze performance, and facilitate payments.

Splayed.ai respects your privacy. This Privacy Policy (this “Policy”) describes how we process Personal Data (as defined below) we gather through in the course of operating the Platform (including if you are a content creator, if you subscribe to use our Platform, or if you sign up for a free trial), when you interact with Splayed.ai, and when you apply for a job at Splayed.ai. It also tells you about your rights and choices with respect to your Personal Data, and how you can contact us if you have any queries or concerns.

By visiting our Site or using any of our Services, you acknowledge that your Personal Data will be handled as described in this Policy. Your use of our Site and Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes.

This Privacy Policy is linked from our application's homepage and explicitly states how Splayed.ai accesses, uses, stores, and shares Google user data, particularly data obtained via the YouTube Data API.

1. Personal Data We Collect

In this Policy, “Personal Data” means any information relating to an identified or identifiable natural person. We may collect and process Personal Data about you in the ways outlined below. Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from our Services if that information is necessary to provide you with them or if we are legally required to collect it.

Information Provided by You Directly

  • Account and Profile Information: If you use the Splayed.ai Platform (as a brand, agency, or creator participating in campaigns), we will ask you to provide us with Personal Data including your name, contact details (e.g., work/personal email address, phone number), company you work for (if applicable), and potentially profile pictures. We will also ask you to create a username and password for access to the Platform. When registering as a creator, you will provide your YouTube channel URL (or channel ID).
  • Payment and Billing Information: For paid services or to receive payments (e.g., creators for Splayed Payments / Splayed Affiliates Payments), we collect billing data such as bank account details (IBAN/BIC/SWIFT/local account number), payment card information, billing address, and tax identification numbers (e.g., PAN, GSTIN, VAT).
  • Campaign Information: Information you provide when creating or participating in influencer marketing campaigns, such as campaign briefs, content requirements, and performance goals.
  • Communications: If you contact us (e.g., via contact form, email, support chat), you may provide Personal Data like your name, contact details, and the content of your communications.
  • Job Applications: If you apply for a job, you may provide Personal Data such as your educational and professional history, CV, references, etc.
  • Voluntary Information: Any other information you choose to provide, such as feedback, survey responses, or content you post on our Platform (if applicable). If you post content, it may become public.

Information We Collect Automatically

  • Usage Data: We automatically collect information about your use of our Site and Services through cookies, server logs, and other tracking technologies: your domain name; your device ID; your browser type and operating system; web pages you view on our Site; links, buttons, or other elements you click; mouse position; text, images, audio and videos from pages you view on our Site; your IP address; the length of time you visit our Site and/or use our Services; and the referring URL, or the webpage that led you to our Site.
  • Publicly Available Creator Information: For our influencer discovery and analytics features (separate from YouTube channel ownership verification), we collect information about Creators and their audience from publicly available resources (e.g., social media platforms, blogs, websites). This may include Personal Data the Creator or their audience has made public, such as name, social media handles, contact details (if public), location, bio, interests, photos, videos, content, and audience demographic estimates.

Information We Access Via Google APIs (YouTube Data API - youtube.readonly scope) for Channel Ownership Verification

When you, as a creator, sign up and provide your YouTube channel URL or ID, Splayed.ai uses the Google Sign-In and YouTube Data API (specifically the youtube.readonly scope) for the sole and limited purpose of verifying that you are the legitimate owner of the YouTube channel you claim.

  • How We Access and Use Data: Immediately after you authenticate with Google and grant permission, our application makes a single, one-time API call to channels.list(mine=true). We retrieve your YouTube Channel ID from this call.
  • Purpose of Access: The retrieved Channel ID is used exclusively to compare against the Channel ID associated with the YouTube channel URL you provided during your Splayed.ai account setup. This confirms your ownership.
  • Data Storage: Splayed.ai does not store the OAuth token granted by you after this one-time verification check. We also does not store any of your YouTube data obtained through this API call (including your Channel ID obtained via the API, or any other data elements like channel name, profile picture, subscriber counts, etc., that might be technically part of the API response but are not used or stored by us beyond the instantaneous ownership check). The permission and any transient data are used only for this instantaneous ownership check and are then discarded from our active processing.
  • Data Sharing: No Google user data obtained through this YouTube API channels.list(mine=true) call for ownership verification is shared with any third party.

By using Splayed.ai features that require YouTube channel ownership verification, you are agreeing to be bound by the YouTube Terms of Service and Google Privacy Policy.

Information We Collect Via Instagram APIs

If you connect your Instagram account to Splayed.ai for features such as campaign management, analytics, or creator discovery (where permitted by Instagram), we may collect the following information via Instagram APIs, in accordance with your authorizations and Instagram's policies:

  • Instagram Profile Data: Your Instagram username, profile picture, bio, follower count, following count, number of posts. For connected business/creator accounts, we may access more detailed profile insights.
  • Instagram Content Data: For accounts you manage and connect, or for public content you ask us to analyze (where permitted): media (photos, videos, stories, reels) URLs, captions, like counts, comment counts, view counts (for videos/reels), reach, impressions, engagement rate, and other performance metrics.
  • Instagram Audience Data: For connected business/creator accounts: aggregated and anonymized audience demographics (e.g., age range, gender, location of followers), and follower growth analytics.
  • Instagram Account Information: Basic account information when you authenticate via Facebook/Instagram.

Your use of Splayed.ai features that access Instagram data is also subject to Instagram's Terms of Use and Data Policy.

Information Collected from Other Third-Party Sources

  • Authentication Services: If you choose to sign in using third-party services like Google (for general Splayed.ai account login, distinct from the specific YouTube channel verification process described above), we receive information such as your name, email address, language preference, and profile picture from them.
  • Business Intelligence Platforms: We may obtain Personal Data (e.g., business contact information) from business intelligence platforms (e.g., ZoomInfo, Clearbit) to identify potential business customers.
  • Payment Processors: Our payment processors may provide us with information related to your payment transactions.

2. How We Use Your Personal Data

We use your Personal Data for the following purposes, based on valid legal grounds (e.g., your consent, performance of a contract, compliance with a legal obligation, or our legitimate interests):

Purpose Description of Use Legal Ground(s)
Providing and Improving Our Services To operate, maintain, and provide all features of our Platform; create and manage your account; facilitate influencer discovery, campaign management, analytics (for Instagram and other non-YouTube API sourced data, or publicly available YouTube data not accessed via user-authenticated API), and payments; personalize your experience; provide customer support; improve and develop new products and features. Performance of contract; Legitimate interest.
YouTube Channel Ownership Verification (Using Google API - youtube.readonly scope) To verify that a user is the legitimate owner of the YouTube channel they claim to own during Splayed.ai account setup. This is achieved via a single, one-time API call to channels.list(mine=true) immediately after the user authenticates. We retrieve the user's Channel ID to match it against the one they've provided. The OAuth token and any retrieved YouTube data are not stored by Splayed.ai after this instantaneous check. Your consent/authorization when authenticating with Google for this specific purpose; Legitimate interest (to ensure platform integrity and prevent impersonation). Subject to Google API Services User Data Policy including Limited Use requirements.
Using Instagram API Data (for Analytics, Campaign Management etc.) To provide Instagram profile and content analytics, help manage Instagram campaigns, identify relevant Instagram creators (based on your connected account or public data), track campaign performance involving Instagram content. All uses are designed to provide or improve prominent user-facing features within Splayed.ai. Your consent/authorization when connecting your account; Performance of contract; Legitimate interest (to provide our core services). Subject to Instagram Platform Policy.
Facilitating Payments (Splayed Payments / Splayed Affiliates Payments) To process payments to creators or affiliates and to bill customers for services. Performance of contract; Legal obligation.
Communicating with You To send administrative information, service updates, security alerts, support messages, respond to inquiries, and request feedback. Performance of contract; Legitimate interest.
Marketing and Promotions To send you news, newsletters, special offers, and promotions about Splayed.ai services that may interest you (you can opt-out). We do not use any Personal Data obtained through the YouTube Data API youtube.readonly scope (used for channel verification) for any marketing or advertising purposes. Consent (where required); Legitimate interest (to market our services).
Analytics and Research (Non-YouTube API Authenticated Data) To monitor and analyze usage trends for our Platform generally, understand how users interact with our Services, and for other research and statistical purposes, both on an aggregated and individualized basis, to improve our Services. This does not involve analysis of data obtained via user-authenticated YouTube API calls beyond the described ownership verification. Legitimate interest.
Security and Fraud Prevention To protect the safety, rights, property, or security of Splayed.ai, our users, and the public; to detect, prevent, or otherwise address fraud, security, or technical issues. Legal obligation; Legitimate interest.
Legal Compliance To comply with applicable laws, regulations, legal processes, or governmental requests; to enforce our Terms of Service and this Policy. Legal obligation; Legitimate interest.
Recruitment To assess your suitability for employment if you apply for a job. Consent; Legitimate interest.
Aggregation and De-identification We may aggregate or otherwise de-identify Personal Data (excluding any data from the YouTube API verification process, which is not stored) for business purposes, such as industry analysis or service improvement. This data will no longer identify you. Legitimate interest.

Google API Services (YouTube Data API) - How Splayed.ai Accesses, Uses, Stores, and Shares Google User Data & Limited Use Disclosure

Splayed.ai's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Specifically for the YouTube Data API (youtube.readonly scope), Splayed.ai's interaction with Google user data is strictly limited as follows:

  1. Access and Use: Our application needs to verify that a user is the legitimate owner of the YouTube channel they claim to own. We use the youtube.readonly scope for a single, one-time API call to channels.list(mine=true) immediately after the user authenticates with Google. We retrieve the user's YouTube Channel ID from this API call. The sole purpose of accessing this Channel ID is to compare it against the Channel ID associated with the YouTube channel URL the user provided during their Splayed.ai account setup. This is a user-initiated process for account security and platform integrity. This use is a prominent user-facing feature related to account setup and verification.
  2. Storage: Splayed.ai does not store the user's OAuth token after this one-time verification is complete. Furthermore, Splayed.ai does not store any of their YouTube data obtained through this API call (such as the Channel ID or any other channel metadata that might be part of the API response). The permission is used only for this instantaneous ownership check, and the token and any transiently retrieved data are then discarded and not stored on our systems.
  3. Sharing: Splayed.ai does not share any Google user data (including the Channel ID obtained for verification or the OAuth token) received through the YouTube Data API with any third parties. The data is not transferred to any other app or service.
  4. Limited Use Compliance:
    • Splayed.ai does not use data obtained via the YouTube Data API (youtube.readonly scope for channel verification) to serve advertisements, including personalized, re-targeted, or interest-based advertising.
    • Splayed.ai does not allow humans to read the data obtained via this API call, as it is processed programmatically for the instantaneous match and then discarded. The only exception would be if required for security purposes (e.g., investigating abuse) or to comply with applicable law, though given our non-storage policy, this scenario is highly unlikely for this specific data.
    • Splayed.ai does not transfer Google API data obtained from this verification process to others.

3. How We Share Your Personal Data (General, excluding YouTube API verification data)

We do not sell your Personal Data. We may share your Personal Data (excluding any Google user data obtained from the YouTube API channels.list(mine=true) call, which is not stored or shared) with third parties in the following circumstances:

  • Service Providers: We work with third-party service providers who perform functions on our behalf (e.g., cloud hosting with AWS, payment processing, customer support tools like Intercom, email services like Sendgrid, analytics providers like Google Analytics). These providers only have access to Personal Data needed to perform their functions and are contractually obligated to protect it and use it only for the purposes for which it was disclosed.
  • API Partners (Instagram): We exchange data with Meta/Instagram (for Instagram services) as necessary to provide the integrated features of our Platform, in accordance with their respective API terms and your authorizations. For example, if you instruct Splayed.ai to analyze an Instagram profile, we will query the respective API.
  • Payment Processors: To facilitate payments, we share necessary information with payment processing companies.
  • Business Transfers: If Splayed.ai is involved in a merger, acquisition, financing, sale of assets, or bankruptcy, your Personal Data may be transferred as part of that transaction. We will notify you of any such deal and outline your choices.
  • Legal Requirements: We may disclose your Personal Data if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  • Protection of Rights: We may disclose Personal Data where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation.
  • Aggregated or De-identified Data: We may share aggregated or de-identified information, which cannot reasonably be used to identify you, with third parties for research, marketing, analytics, or other purposes.
  • With Your Consent: We may share your Personal Data with other third parties with your explicit consent.

4. Data Retention

We retain Personal Data for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law (e.g., for tax, accounting, or other legal requirements like DPDPA). When determining retention periods, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and applicable legal requirements.

  • Account Data: Retained while your account is active and for a reasonable period thereafter (e.g., 3-5 years) for legitimate business purposes or as required by law.
  • YouTube API Data for Channel Verification: As stated explicitly in Sections 1 and 2, Splayed.ai does not store the OAuth token or any Personal Data obtained from your YouTube account via the channels.list(mine=true) API call beyond the immediate, one-time verification process. This data is discarded and not retained.
  • Instagram API Data: Data obtained via Instagram APIs (for analytics, campaign management, etc.) is retained as long as necessary to provide the services you've authorized or requested, or until you revoke access. If you revoke access, or if the data is no longer needed for the approved purpose, we will delete it in accordance with Instagram's platform policies and our data retention schedules. We periodically review and delete stale API data.
  • Invoicing and Payment Data: Retained for at least 7-8 years as required by Indian tax and company laws.
  • Backups: Maintained for business continuity for a limited period. Backups will not contain YouTube API tokens or data from the channel verification process due to our non-storage policy for that specific data.

5. Your Rights and Choices

Depending on your location and applicable law (e.g., GDPR, DPDPA), you may have certain rights regarding your Personal Data:

  • Right to Access: To request a copy of the Personal Data we hold about you.
  • Right to Rectification: To request correction of inaccurate Personal Data.
  • Right to Erasure (Deletion): To request deletion of your Personal Data, subject to certain exceptions (note: for YouTube channel verification data, we do not store it, so there is no stored data to erase from our systems post-verification).
  • Right to Restrict Processing: To request restriction of how we process your Personal Data in certain circumstances.
  • Right to Data Portability: To receive your Personal Data in a structured, commonly used, machine-readable format and to transmit it to another controller.
  • Right to Object: To object to our processing of your Personal Data (e.g., for direct marketing).
  • Right to Withdraw Consent: If we process your Personal Data based on your consent (such as consenting to Google Authentication for YouTube channel verification or Instagram API access), you can withdraw it at any time. For Google/YouTube data, this is done via Google's security settings. For Instagram, via Instagram/Facebook settings. This will not affect the lawfulness of processing based on consent before its withdrawal.
  • Right to Lodge a Complaint: To lodge a complaint with your local data protection authority (e.g., the Data Protection Board of India, once fully operational).

To exercise these rights for data managed by Splayed.ai (excluding revoking API access which is done via the respective platforms), please contact us using the details in Section 15 ("Our Contact Information"). We will respond to your request in accordance with applicable law and may need to verify your identity.

Revoking Access to Google and Instagram Data

  • Google/YouTube Data: You can revoke Splayed.ai's access to your Google account data at any time via the Google security settings page at https://myaccount.google.com/permissions. As Splayed.ai does not store the OAuth token or data from the channel verification process, revoking access primarily prevents future verification attempts if needed (e.g., if we were to re-verify for some reason, though this is not our current practice for this specific, one-time check).
  • Instagram Data: You can manage and revoke Splayed.ai's access to your Instagram data through your Instagram account settings (typically under "Apps and Websites" or a similar section in your Instagram or Facebook settings if linked). Upon revocation, we will no longer be able to access your Instagram data for features like analytics or campaign management and will delete existing stored Instagram data according to this Policy and Instagram's requirements.

6. Third-Party Links

Our Platform may contain links to third-party websites or services. We are not responsible for their privacy practices. This Policy does not apply to third-party websites or services. We encourage you to read their privacy policies.

7. Security

Splayed.ai takes reasonable and appropriate administrative, technical, and physical security measures to protect your Personal Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Data. However, no internet or email transmission is ever fully secure or error-free, so you should take special care in deciding what information you send to us.

8. Children’s Privacy

Our Services are not directed to children under the age of 18 (or the relevant age of digital consent in their jurisdiction). We do not knowingly collect Personal Data from children under 18. If we learn that we have collected Personal Data from a child under 18 without verification of parental consent (where required), we will take steps to delete that information. If you are a parent or guardian and believe your child has provided us with Personal Data, please contact us. For users of YouTube features, we also adhere to age restrictions imposed by YouTube (typically 13+ or age of digital consent).

9. Cross-Border Data Transfers

Your Personal Data may be transferred to, stored, and processed in countries other than your own, including India (where Splayed.ai is headquartered) and countries where our service providers are located (e.g., USA for AWS). These countries may have data protection laws that are different from the laws of your country. When we transfer Personal Data across borders, we take appropriate safeguards to protect your Personal Data in accordance with this Policy and applicable law (e.g., by using Standard Contractual Clauses for transfers from the EEA/UK, or ensuring adequacy decisions, or other recognized transfer mechanisms).

10. Changes to this Policy

We may update this Policy from time to time. If we make material changes, we will notify you by updating the "Effective Date" at the top of this Policy and, where required by law or in case of significant changes, by providing a more prominent notice (e.g., via email or an in-app notification). We encourage you to review this Policy periodically.

11. Our Use of Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Site and Services. We may combine this information with other Personal Data we collect from you.

  • Cookies: These are small text files stored on your device. Some cookies allow us to make it easier for you to navigate our Site and Services (session cookies), while others are used to track your activities (persistent cookies) or enable certain functionalities. You can usually manage cookie preferences through your browser settings, but disabling cookies may affect some features. We may use cookies for functionality, performance/analytics, and (where permissible and with consent if required) for targeting/advertising of Splayed.ai's own services.
  • Clear GIFs (Pixel Tags, Web Beacons): Tiny graphics with a unique identifier, used to track online movements of web users or to see if emails have been opened.
  • Local Storage Objects (LSOs): We may use LSOs (e.g., HTML5 local storage) to store content information and preferences.
  • Third-Party Analytics: We use tools like Google Analytics to evaluate usage of our Site and Services. These tools use cookies and other technologies to collect usage data. For Google Analytics, you can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt-out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

For more detailed information on the cookies we use, their purpose, and how to manage them, please refer to our Cookie Policy.

Do Not Track: Currently, our systems do not recognize browser “do-not-track” requests. However, you can disable certain tracking as discussed in this section (e.g., by disabling cookies).

12. Direct Marketing

We may send periodic promotional emails to you about Splayed.ai's services. You may opt-out of such communications by following the opt-out instructions contained in the email, by updating your marketing preferences in your Splayed.ai account settings, or by contacting us. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any Services you have requested or received from us (transactional emails).

13. Information for EU/EEA/UK Individuals (GDPR/UK GDPR)

If you are in the European Economic Area (EEA) or the United Kingdom (UK), the following additional information applies to you:

  • Data Controller: Splay technologies private limited is the data controller for the processing of your Personal Data.
  • Legal Bases for Processing: We process your Personal Data based on the legal bases described in Section 2 ("How We Use Your Personal Data"). This includes processing necessary for the performance of a contract with you, compliance with a legal obligation, our legitimate interests (provided they are not overridden by your rights), or your consent (where applicable).
  • Your Rights: You have the rights as outlined in Section 5 ("Your Rights and Choices"), including the right to access, rectify, erase, restrict processing, data portability, object to processing, withdraw consent, and lodge a complaint with a supervisory authority.
  • Cross-Border Transfers: As stated in Section 9, if we transfer your Personal Data outside the EEA/UK to countries not deemed adequate by the European Commission or UK Government, we rely on appropriate safeguards such as Standard Contractual Clauses.

14. Information for California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) may provide you with additional rights regarding your Personal Data. Splayed.ai aims to comply with these rights for its California users.

  • Categories of Personal Information Collected: In the preceding 12 months, we may have collected categories of personal information as described in Section 1 ("Personal Data We Collect"). These may include: identifiers (name, email, IP address), customer records information, commercial information (services purchased), internet or other electronic network activity information (usage data), geolocation data (general, from IP), and inferences drawn to create a profile about preferences or characteristics. We do not collect sensitive personal information as defined by CPRA for general users; for YouTube channel verification, we access your Channel ID as described, but do not store it.
  • Business or Commercial Purposes for Collection: As described in Section 2 ("How We Use Your Personal Data").
  • Categories of Sources: As described in Section 1.
  • Categories of Third Parties with Whom We Share/Disclose Personal Information for a Business Purpose: As described in Section 3 ("How We Share Your Personal Data"), this may include service providers, API partners (Instagram), payment processors. We do not share YouTube API verification data.
  • "Sale" or "Sharing" of Personal Information: Splayed.ai does not "sell" Personal Data in the traditional sense (exchange for monetary compensation). Under CCPA/CPRA, "sharing" for cross-context behavioral advertising may also be considered a "sale." We do not use Personal Data obtained from Google APIs (including the YouTube Data API youtube.readonly scope for channel verification) for such advertising. For other data, if our use of certain advertising cookies or analytics constitutes "sharing" under CCPA/CPRA, you may have the right to opt-out. Please refer to our Cookie Policy for choices regarding cookies.
  • Your California Privacy Rights:
    • Right to Know/Access: To request disclosure of the specific pieces and categories of personal information we have collected about you, categories of sources, business/commercial purposes for collecting/selling/sharing, categories of third parties to whom we disclose, and categories of personal information disclosed for a business purpose or sold/shared.
    • Right to Delete: To request deletion of your personal information, subject to certain exceptions.
    • Right to Correct: To request correction of inaccurate personal information.
    • Right to Opt-Out of Sale/Sharing: To opt-out of the "sale" or "sharing" of your personal information (as defined by CCPA/CPRA).
    • Right to Limit Use and Disclosure of Sensitive Personal Information (SPI): We do not generally collect SPI as defined by CPRA. If we were to do so, its use would be limited to permitted purposes under the law.
    • Right to Non-Discrimination: You will not be discriminated against for exercising your CCPA/CPRA rights.
  • Exercising Your Rights: To exercise your California privacy rights, please contact us as per Section 15. We will verify your request using the information associated with your account. You may also designate an authorized agent.
  • Shine the Light: California residents may request once a year a list of certain third parties to whom we have disclosed their personal information for such third parties' direct marketing purposes in the preceding calendar year. Splayed.ai does not share personal information with third parties for their own direct marketing purposes without your consent.

15. Our Contact Information

Should you have any queries regarding this Policy, about Splayed.ai's processing of your Personal Data, or if you wish to exercise your rights with respect to your Personal Data, you can contact Splayed.ai's Data Protection Officer (or privacy team) by email: support@splayed.ai (Please create and use this email or a similar dedicated one) or by writing to us at:

Splay technologies private limited
Attn: Privacy Department / Data Protection Officer
Villa no-50, Windmills of your mind, Whitefield
Bangalore South, Bangalore- 560066
Karnataka, India