Privacy Policy

Data Controller

The data controller for personal data processed in connection with the BibleChat Creator Programme is BookVitals App SRL, a company incorporated under the laws of Romania, with its registered office at 22-26 Siriului Street, 3rd floor, Bucharest, District 1, Romania, registration no. J2024012185403 (“Company”, “we”, “us”, or “our”). For data protection matters, you can contact us at: influencers@thebiblechat.com

1. Introduction

This Privacy Policy describes how the Company processes the personal data of applicants to and participants in the BibleChat Creator Programme (“Programme”). It applies to data collected through the application form, during onboarding, and throughout your participation in the Programme.

By submitting an application or participating in the Programme, you confirm that you have read and understood this Privacy Policy and the basis on which we process your personal data.

This Privacy Policy is supplemented by, and should be read alongside, the Creator Programme Terms and Conditions, which govern the contractual relationship between you and the Company.

2. Data We Collect

2.1 Application data

When you apply to the Programme, we collect:

• Full name
• Email address
• Phone / WhatsApp number
• Country of residence
• Links to your existing social media profiles (TikTok, Instagram, and any others you provide)
• Application source (referral, landing page, advert)
• Where applicable, the email address of the Creator who referred you

2.2 Onboarding data

After acceptance into the Programme, we collect:

• Discord username (used for the Creator’s private Discord channel, which is the designated channel for delivering Created Videos)
• Tax compliance information (W-8BEN form data, as required by the Payment Platform under United States tax law)
• Handles for the Programme Accounts you create for the Programme
• Bank account information or equivalent payment details, processed exclusively through the Payment Platform

2.3 Operational data

Throughout your participation in the Programme, we process:

• The Created Videos and Published Videos you produce under the Programme (as defined in the Terms and Conditions)
• View counts and other engagement metrics reported by the Platforms for your Published Videos
• Records of the Brief Compliance audit — whether your Created Videos and Published Videos meet the Brief Compliance rules, including written reasons recorded by the Company in case of non-compliance
• Records of key events in your participation (acceptance date, first post date, monthly performance review dates, eligibility decision dates, where applicable)
• Communications between you and Company staff (including but not limited to WhatsApp, email, and Discord messages)
• Compensation records (base rate, bonuses, payments)

2.4 Sources of data

Personal data is collected:

• Directly from you, when you apply, complete onboarding, or communicate with us
• From the Platforms, in the form of view counts and engagement metrics for your Published Videos
• From the Payment Platform, in the form of payment status and tax compliance confirmations

3. Purposes of Processing

We process your personal data for the following purposes:

• Evaluating and accepting your application. To assess your suitability for the Programme and decide on acceptance.
• Administering the Programme. To onboard you, communicate with you about briefs and updates, manage your participation, and evaluate your performance.
• Calculating and paying compensation. To calculate the base rate, view-based bonuses, and Monthly Stage Bonus, and to transmit the corresponding amounts to the Payment Platform for payment.
• Determining eligibility. To assess your participation against the Programme’s operational metrics and make eligibility decisions.
• Brief Compliance audit. To verify whether your Created Videos and Published Videos meet the Brief Compliance rules, and to record the reasons for any non-compliance decision.
• Legal compliance. To meet tax, accounting, and other regulatory obligations.
• Fraud prevention and security. To detect and prevent abuse, including artificial inflation of view counts.
• Paid media use. To select top-performing Published Videos for use in paid advertising campaigns promoting BibleChat, in accordance with Section 5.2 of the Terms and Conditions. Legal basis: performance of a contract (Article 6(1)(b) UK GDPR).

The legal basis for each processing activity is one or more of the following:

• Performance of a contract (Article 6(1)(b) UK GDPR) — for processing necessary to administer the Programme, calculate compensation, conduct the Brief Compliance audit, and make eligibility decisions.
• Compliance with legal obligations (Article 6(1)(c) UK GDPR) — for processing necessary to comply with tax, accounting, and other applicable law.
• Legitimate interests (Article 6(1)(f) UK GDPR) — for fraud prevention, security, and improving the Programme. Where we rely on legitimate interests, we have carried out a balancing test to confirm that our interests do not override your rights and freedoms; you can request information about this balancing test by contacting us at the address in Section 11.

4. Sharing Data with Third Parties

We share your personal data with:

• The Payment Platform, a performance-based payment infrastructure based in the United States, for the purpose of making payments to you. The Payment Platform acts as a separate data controller for the data it processes for payment purposes and operates under its own Privacy Policy. Categories of data shared: name, email, country of residence, W-8BEN data, payment amounts, payment metadata.
• Discord (Discord Inc., United States), as a processor providing the messaging infrastructure used as the designated channel for delivering Created Videos under the Terms and Conditions. Categories of data shared: Discord username, message content, file attachments (Created Videos).
• The Platforms (TikTok, Instagram, Facebook, YouTube, etc.), indirectly, in that your Programme Accounts and Published Videos on them are public on the relevant Platforms and are subject to the Platforms’ own data processing.
• Tax and accounting service providers, where necessary for legal compliance.
• Hosting and IT service providers, who process data on our behalf under contractual data processing agreements.
• Legal and regulatory authorities, where required by law.
• Advertising platforms and media-buying partners (e.g. TikTok Ads Manager, Meta Ads Manager, YouTube Ads), for the purpose of running Published Videos selected under Section 5.2 as paid advertising. Categories of data shared: the Published Video itself, including the Creator’s image, voice, and likeness as they appear in it.

We do not sell your personal data to third parties.

5. International Data Transfers

Some of our service providers, including the Payment Platform and Discord, are based in the United States. Your personal data may therefore be transferred to and processed in countries outside the United Kingdom, including the United States.

Where personal data is transferred outside the UK, we rely on the following safeguards:

• For transfers to recipients certified under the UK Extension to the EU-U.S. Data Privacy Framework, the Framework provides an adequate level of protection for that transfer.
• For transfers to recipients not certified under the Data Privacy Framework, we rely on the International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, completed, where applicable, by additional technical and organisational measures.

You can request a copy of the relevant safeguards by contacting us at the address in Section 11.

6. Data Retention Periods

We retain your personal data for the following periods:

• Application data for unsuccessful applicants: deleted within twelve (12) months of the application date, unless you have given separate consent to longer retention.
• Active Programme participants: data is retained for the duration of your participation, plus an additional period necessary for legal compliance — ten (10) years from the end of the financial year, in accordance with Romanian accounting law, as the Company is a Romanian entity.
• Creators found not currently eligible for new briefs (Section 10.3 of the Terms and Conditions): data is retained on the same basis as active Programme participants, as an eligibility decision under Section 10.3 is not a termination and the Creator may be re-engaged.
• Communication records: retained for three (3) years from the date of communication, unless a longer period is required for legal or contractual reasons.
• Unsuccessful Qualification Submissions (Section 2.3 of the Terms and Conditions): the Created Video is deleted within thirty (30) days of the negative decision, except where retention is required for fraud prevention or legal compliance. Records of the decision itself (date, outcome, reasons) are retained for the period necessary for legal compliance.

7. Your Rights

You have the following rights under applicable data protection law:

• The right to access the personal data we hold about you
• The right to rectification of inaccurate or incomplete data
• The right to erasure of data (“right to be forgotten”), subject to legal retention obligations
• The right to restriction of processing
• The right to data portability
• The right to object to processing based on legitimate interest
• The right to withdraw your consent, where processing is based on consent (without affecting the lawfulness of processing before withdrawal)
• The right to lodge a complaint with a supervisory authority

The competent supervisory authority for the United Kingdom is:

To exercise any of these rights, contact us at influencers@thebiblechat.com. We will respond within one (1) month of receiving your request, in accordance with Article 12 UK GDPR.

8. Cookies

This Privacy Policy addresses the processing of personal data within the Creator Programme. The Programme itself does not rely on cookies or similar tracking technologies for its core operation. However, the Programme’s landing pages on the Company’s websites use cookies for essential site functionality, analytics, and (where you give consent) marketing purposes. The use of cookies on the Company’s websites is described in a separate Cookie Policy, available on the relevant landing page.

The Platforms (TikTok, Instagram, etc.) and the Payment Platform use cookies and similar technologies on their own services in accordance with their own policies, over which the Company has no control.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction, in accordance with Article 32 UK GDPR. These measures include, without limitation:

• Encryption of personal data in transit and, where applicable, at rest
• Access controls limiting access to personal data to authorised staff on a need-to-know basis
• Regular review of access permissions
• Contractual data processing agreements with all third-party service providers, including the Payment Platform, Discord, and hosting providers
• Incident response procedures for detecting, investigating, and notifying personal data breaches, in accordance with Articles 33 and 34 UK GDPR

No system can guarantee absolute security. In the event of a personal data breach affecting your data, we will notify the competent supervisory authority within 72 hours, where required, and will notify you directly if the breach is likely to result in a high risk to your rights and freedoms.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to active Programme participants by email at least seven (7) days before taking effect. The “Last updated” date at the top of this document reflects the most recent revision.

11. Contact

For data protection matters, including exercising your rights under Section 7, contact us at:

By participating in the BibleChat Creator Programme, you confirm that you have read and understood this Privacy Policy.