Creator privacy notice

ComniWell ("ComniWell", "we", "us") is a sole proprietorship (eenmanszaak) registered with the Dutch Chamber of Commerce (KVK) under number 42155849, at Hoogstraat 16, 7512 GX Enschede, Overijssel, Netherlands. Contact: support@comniwell.com. We are the data controller for your personal data under the GDPR.

This notice covers you as a creator: someone we contacted about the programme, an applicant, or a partner. If you also use the ComniWell app yourself, your app data is covered separately by our main Privacy Policy.

We look for creators whose public content fits ComniWell, and we may message you once about the programme, with one follow-up.

• What we hold: your public handle and profile link, platform, follower count, an estimate of engagement, content topic, language, country if you show it, a business email address if you publish one, the message we sent, and your reply.
• Where it comes from: your public profile.
• We do not record anything about your health, even if you post about it.
• Why, and on what basis: our legitimate interest in finding partners for the programme.
• Who handles it: Google (spreadsheet), Zoho (email, on its EU data centre) and Anthropic (helps us draft messages from what is on your public profile). Google and Anthropic may process data outside the EEA.
• How long: if we never send you a message, we delete your details within 30 days. If we did message you, we keep your handle, the date and the bio text that invited contact for 5 years, as proof that we were allowed to. If you do not reply, we delete the rest after 6 months.
• To stop: reply "stop" or email support@comniwell.com at any time. We then delete your details and keep only what we need to not contact you again.

• Application data: the name, email, WhatsApp number, and social handle you give us when you apply at comniwell.com/creators.
• Referral and commission records: your referral code, a record of each subscriber referred through it, the commission and bonus amounts, and payment status. This is how we calculate and prove what we owe you. You see totals and never who subscribed.
• Payout details: your bank account or PayPal details, provided so we can pay you.
• Terms acceptance record: which version of the creator terms you accepted, when, and the IP address you accepted from, kept as evidence in case a rate or a term is ever disputed.
• VAT number, if you give us one.
• Tax details, asked at your first payout. Everyone: legal name, country of residence, and whether you are a private person or a business. Businesses: trade name, business address, KVK or equivalent number, VAT number, and whether you use a small-business VAT scheme. Private persons, or if you charge no VAT: address and date of birth. We never ask for your BSN.
• Statements: what we paid you and when, and the value of any free Premium.
• Post records: links to posts you send us, and what we checked or asked you to change.
• Your app account, so we can give you free Premium and show you your earnings, and which friend codes went to you.
• WhatsApp number and messages: we use WhatsApp to manage the relationship directly. WhatsApp is operated by Meta, which processes messages sent through it under its own terms. This can involve a transfer of your data outside the EEA.

• Contract: to run the creator partnership, track referrals, calculate commission and bonuses, give you free Premium, and pay you.
• Legal obligation: bookkeeping and tax records, invoices and statements, and any report the Dutch tax authority (Belastingdienst) requires about payments.
• Legitimate interest: to prevent fraud (such as self-referral), to check posts against advertising rules as the Dutch advertising code requires of us, and to keep a record of what was agreed in case of a dispute.

A small number of service providers, processing data on our instructions, and authorities where the law requires:

• Supabase: stores your creator and referral records. Hosted in the eu-west-1 (Ireland) region.
• Cloudflare: runs the application and terms-acceptance forms on comniwell.com.
• RevenueCat: subscription records used to credit referrals and give you free Premium.
• WhatsApp / Meta: for direct communication, as described above.
• Our bank or PayPal, to send you a payment.
• The Belastingdienst, if we are required to report what we paid you.

We do not sell your data or share it with advertisers or data brokers.

Referral, commission, tax, statement and payout records are kept as long as Dutch tax and bookkeeping law requires (currently 7 years), even after the partnership ends. If your application is rejected, or you never activate a code, we delete your application data within 12 months. People who never replied to us: see above.

You can ask to access, correct, export, or delete your data, and you can object to processing based on our legitimate interest, by emailing support@comniwell.com. If you object to us contacting you about the programme, we always stop. Some records (such as commission and tax records) we are legally required to keep regardless of a deletion request. You may also complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

We will update this page and change the "Last updated" date if what we collect or why changes.