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: [email protected]. We are the data controller for your personal data under the GDPR.

This notice is about you as a ComniWell creator partner -- not as an app user. If you also use the ComniWell app yourself, your app data is covered separately by our main Privacy Policy.

• 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, and a record of each subscriber referred through it, the commission amount, and its payment status -- this is how we calculate and prove what we owe you.
• Payout details: your bank account or PayPal details, provided so we can pay you.
• Terms acceptance record: which version of these 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.
• WhatsApp number and messages: we use WhatsApp to manage the relationship directly -- onboarding, questions, and rate-change notices. 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 pay you.
• Legal obligation -- bookkeeping and tax records we're required to keep as a business.
• Legitimate interest -- to prevent fraud (e.g. checking for self-referral) and to keep a record of what was agreed, in case of a dispute.

A small number of service providers, processing data only on our instructions:

• 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.
• WhatsApp / Meta -- for direct communication, as described above.
• Our bank or PayPal, to actually send you a payment.

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

Referral, commission, and payout records are kept as long as Dutch tax and bookkeeping law requires business records to be kept (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.

You can ask to access, correct, export, or delete your data, and you can object to processing based on our legitimate interest, by emailing [email protected]. Some records (e.g. commission and tax records) we're legally required to keep regardless of a deletion request. You may also complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

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