Who we are
The data controller is Content & Emotion S.L. (hereinafter “cyrqle”, “we”, “us”), a Spanish limited company with registered office in Madrid, Spain. For privacy questions, contact privacy@cyrqle.app.
Our Data Protection Officer (DPO) can be reached at the same address. Where required, we maintain a Data Processing Agreement (DPA) with brand and agency customers and with technical sub-processors.
What we collect
We collect the following categories of personal data:
- Account data — name, email, role (Brand / Creator / Agency), authentication identifiers from Google, Instagram, LinkedIn, or TikTok when you sign in.
- Profile data — handles, links, audience demographics, content metadata, performance signals associated with creator profiles.
- Campaign data — briefs, drafts, approvals, deliverables, attribution events, payouts.
- Payment data — handled by Stripe Connect; we receive limited metadata (last 4 digits, country, status) but never full card numbers.
- Usage data — pages visited, device, browser, IP, referer, session duration. Collected via first-party analytics; no third-party cookies.
Why we process it (lawful basis)
We rely on the following GDPR lawful bases:
- Contract — to provide the cyrqle platform you signed up for.
- Legitimate interests — to operate, secure, improve and market cyrqle, balanced against your fundamental rights.
- Consent — for non-essential cookies and direct marketing.
- Legal obligation — accounting, tax, fraud prevention.
International transfers
Cyrqle is built EU-first. Our primary data residency is in the EU (Cloudflare R2 EU, EU PlanetScale region). Where transfers leave the EEA — for example to AI inference providers — we rely on EU Standard Contractual Clauses (SCCs) and supplementary measures including encryption in transit and at rest.
How long we keep data
We retain personal data only as long as necessary:
- Account data — for the life of your account, plus 6 months after deletion.
- Campaign records — 6 years (required for tax/accounting in Spain).
- Marketing list — until you unsubscribe.
- Server logs — 90 days.
Your rights
Under GDPR you can request:
- Access to your data and a copy in portable form.
- Rectification of inaccurate data.
- Erasure (“right to be forgotten”) where applicable.
- Restriction of processing or objection to it.
- Withdrawal of consent at any time.
- Lodging a complaint with the Spanish data protection authority (AEPD).
Reach us at privacy@cyrqle.app — we respond within 30 days.
Changes to this policy
When we materially change this policy, we’ll post the update on this page and, if the change affects you, notify you by email at least 14 days before it takes effect.