Zephyrian Creators

Zephyrian Creator Platform: Privacy Policy

Last updated: October 5, 2026

1. Who is responsible for your data

Korpi Venture Oy, Painikuja 12, 70840 Kuopio, Finland, Business ID 3468479-7 ("Zephyrian", "we", "us") is the data controller for the Zephyrian Creator Program and the platform at creators.zephyrian.shop (the "Platform"). Contact: creators@zephyrian.shop. Zephyrian is a group of companies. Another company in our group, or a company that takes over the Program, may become the controller in our place. If that happens we tell you by email, update this policy with the new company's details, and the safeguards in this policy continue to apply. In the United States, Glow Imports LLC, 1309 Coffeen Avenue STE 1200, Sheridan, WY 82801, United States, ships product on our behalf and receives your shipping details for that purpose.

2. What this policy covers

This policy covers the Platform and the Program: applying, taking part, submitting content, connecting your social accounts, partnership ads, rewards and payouts, the messages between us, and how we look for new creators. The Zephyrian online store at zephyrian.shop has its own Privacy Policy, which covers purchases and the store website.

3. What we collect

  • When you apply: your name, email address, Instagram and TikTok handles, country, and what you write in the application. If you apply through a form on Instagram or Facebook (a Meta lead form), Meta passes your answers to us.
  • When you join: the shipping address for product, gifts and other items we send you, your signed creator agreement, and the payout details you give us (for example your PayPal email).
  • While you take part: your personal discount code and tracked links, the orders made with them (order number, amount and date), and the performance of content we run as ads (impressions, clicks, attributed sales). This performance data comes from our store system (Shopify) and from the advertising platforms (Meta, TikTok) through their integrations. We never show you the identity of the customers behind those orders.
  • Content you submit through the Platform, including the videos and images themselves and anything you say about them. Inside the Platform, other creators in the Program may see your accepted content, its performance figures, what it has earned, and leaderboards that rank creators and content, shown with your name or handle. None of this is public. You can ask to appear anonymously on leaderboards.
  • If you connect your Instagram or TikTok account: we receive from Meta or TikTok your account id and username and the public posts you have published, and we store an access token, encrypted, so we can fetch new posts. We use this only to see which of your posts feature Zephyrian and to build a library of that content for the Program. We do not post, message or act on your behalf. The connection is made in Meta's or TikTok's own login window for our app "Zephyrian Creator Program"; we never see or ask for your password.
  • If your track includes partnership ads: we may send you a partnership ads request from Zephyrian's Instagram account through Meta's platform. Meta delivers the request to you inside Instagram, and only you can approve it. We receive from Meta only whether the request is pending, approved or declined.
  • Messages you exchange with us by email, through the Platform, or on Instagram or TikTok. We may use automated tools, including AI, to draft replies and to review submissions. Decisions about your participation and about prizes are made by people.
  • Challenges and prizes: your entries, results, and the details needed to hand over a prize (for example travel details or tax identification). Winners may be announced inside the Platform with name or handle, never publicly without your consent.
  • How you use the Platform: IP address, approximate location derived from it, browser and device type, the pages you open and the buttons you click, which may be collected with analytics tools such as PostHog. Where the law requires consent for this, we ask first (section 6). If session replay is switched on, it records how you move through the pages with typed input masked. Our web server keeps standard access logs with your IP address for security.

We do not collect sensitive personal data, and we do not ask for card or payment details. Payouts go to you, never from you.

4. Why we use it and on what legal basis

  • To run the Program with you (review your application, ship product, give you a dashboard, review your submissions, calculate and pay rewards, communicate with you): performance of a contract.
  • To keep accounting and tax records of payments made to you: legal obligation.
  • To keep the Platform secure, prevent fraud (such as self referrals or misuse of codes) and improve the Program and the Platform, including by analysing how the Platform is used: our legitimate interests, balanced against yours.
  • To find new creators and to manage our recruiting ads. We may share a hashed (scrambled) version of your email address or phone number with Meta or another advertising platform so it can show our recruiting ads to people similar to our creators, or so it can stop showing them to people who already take part or took part in the past. The platform cannot read the hashed value and uses it only for matching. Legal basis: our legitimate interest in running the Program; where the law requires consent, we ask for it. You can object at any time (section 10).
  • To fetch your public posts from Instagram or TikTok after you connect an account: your consent, which you can withdraw by disconnecting the account.
  • For analytics cookies and similar tools on the Platform, where the law requires consent: your consent, given in the cookie banner.

We do not use your data for automated decisions that have legal effects on you. Decisions about applications and submissions are made by people.

5. Who we share it with

We share your data only with companies that process it for us, or with platforms that process it under their own terms, and only as far as needed:

  • Hosting: the Platform runs on our own servers hosted by DigitalOcean, LLC in New York, United States. Backups are stored with the same provider in the same location.
  • Shipping: Glow Imports LLC and the carriers it uses receive your name and shipping address.
  • Store systems: Shopify Inc. processes the product orders we create for you and the orders attributed to your code.
  • Payouts: our payout provider (PayPal) receives your payout details and the amount when we pay you.
  • Email and documents: Google Workspace for email and for the content folders we share with you. Automatic emails from the Platform (for example a sign-in link or a payout notice) are sent through Klaviyo, which processes your name and email address for that purpose.
  • Agreements: you sign your creator agreement inside the Platform by reading and accepting it. We store the accepted text with the date and time. No outside e-signature service is involved.
  • Support messages: Commslayer processes messages you send us by email or Instagram.
  • Analytics: PostHog or a similar tool may process the usage data described in section 3 on our behalf. The Cookie Policy says whether such a tool is in use.
  • Advertising platforms: Meta Platforms and TikTok process the data described in sections 3 and 4 under their own terms when you connect an account, approve a partnership ads request, apply through one of their forms, or when we use hashed contact details for audiences.

We do not sell your personal data. Sharing hashed contact details with an advertising platform for audiences, described in section 4, may count as "sharing" under California law, and section 10 tells you how to opt out. We disclose data to authorities only when the law requires it.

6. Cookies and similar tools

The Platform uses necessary cookies to keep you signed in and to protect forms. It may also use analytics tools such as PostHog, and advertising tools such as the Meta pixel, to understand how the Platform is used and to measure our recruiting ads. Where you are in a region that requires consent for these tools, we ask for it in a banner before they load and you can change your choice at any time. Where your region gives you an opt out instead, the "Your privacy choices" link at the bottom of every page does that, and we honor the Global Privacy Control browser signal. The full list of cookies is in the Cookie Policy.

7. International transfers

We are based in Finland and most creators are in the United States, so your data moves between the European Union and the United States. We and our group companies may also process your data in other countries where we operate. Where we transfer data out of the European Economic Area or the United Kingdom we rely on the European Commission's Standard Contractual Clauses, an adequacy decision or another safeguard the law recognizes. Where a provider in another country processes data of EU or UK residents, the same safeguards apply.

8. How long we keep it

  • Application data of creators we do not accept: 12 months after the decision, then deleted.
  • Program data: while you take part, and afterwards for as long as accounting law requires for payments made to you. In Finland that is six years after the end of the financial year.
  • Content you submitted that we accepted: for as long as the license in your Agreement runs.
  • Access tokens for connected accounts: deleted when you disconnect the account or leave the Program.
  • Hashed contact details used for advertising audiences: refreshed from our current records and removed when you ask us to stop (section 10).
  • Usage data from analytics tools: 12 months, then deleted or made anonymous.
  • Messages: three years after the last message, unless a longer period is needed for a dispute.

9. Deleting your data and disconnecting accounts

To disconnect Instagram or TikTok, use the connections settings in the Platform. This deletes the stored token. To delete your Program data, including the data we received from Meta or TikTok and your hashed contact details in advertising audiences, use Settings, Delete account in the Platform, or email creators@zephyrian.shop from the address you joined with. We confirm once the deletion is done, normally within 30 days. Records we must keep by law (paid rewards) are kept for that period only and for nothing else. Content you licensed to us is handled as your Agreement says. Step by step instructions are on the Delete your data page.

10. Your rights

If you are in the European Economic Area or the United Kingdom, you have the right to access your data, correct it, delete it, restrict or object to its processing (including to its use for finding new creators), receive a copy in a portable format, and withdraw consent at any time. You can complain to the Finnish Data Protection Ombudsman (tietosuoja.fi) or to the authority in your own country.

If you are in California or another US state with a privacy law, you have the right to know what personal information we collect, use and disclose, to delete it, to correct it, to opt out of its sale or sharing for cross context behavioral advertising, to limit the use of sensitive personal information (we collect none), and not to be discriminated against for using these rights. To opt out of sharing, use the "Your privacy choices" link at the bottom of any page or email creators@zephyrian.shop. We honor the Global Privacy Control signal from your browser. You may use an authorized agent. We verify requests by email to the address on your account.

To use any right, email creators@zephyrian.shop. We answer within the time the law gives us, normally 30 days.

11. Security

The Platform runs over HTTPS. Access tokens are stored encrypted. Access to your data is limited to the people who run the Program. You sign in with your email address and a password. If you forget it, we email you a link to set a new one. Where the option is shown, you can also sign in with your Google account. Your Platform login is separate from Instagram, TikTok and Facebook, and we never ask for your password on those services.

12. Age

The Program is open to people aged 18 and over. We do not knowingly collect data from anyone younger. If you believe we have, tell us and we will delete it.

13. Changes to this policy

We may update this policy. We post the new version here with a new "last updated" date and email you if the change affects you materially.

14. Contact

Korpi Venture Oy, Painikuja 12, 70840 Kuopio, Finland. Email: creators@zephyrian.shop.

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