Privacy Policy

1. Who We Are#

UGC Era operates a global user-generated content agency and creator marketplace connecting brands, businesses and UGC Creators.

For most personal information processed through our website and services, UGC Era acts as the data controller, meaning that we determine why and how your personal information is processed.

Data Controller

UGC Era Business/legal name: UGC Era Website: ugcera.com Email: hi@ugcera.com

For privacy requests or data protection complaints, please contact:

hi@ugcera.com

Please include "Privacy Request" or "Data Protection Complaint" in the subject line where appropriate.

Where we process personal information solely on the documented instructions of a business customer, that customer may instead be the controller and UGC Era may act as a processor. In those circumstances, the relevant customer agreement or Data Processing Agreement may contain additional terms.

2. Scope of This Privacy Policy#

This Privacy Policy applies to personal information collected through or in connection with:

• ugcera.com and associated UGC Era webpages;
• UGC Era Creator profiles;
• Creator applications;
• Brand and business accounts;
• the UGC Era marketplace;
• campaign briefs and project applications;
• UGC Creator sourcing and matching;
• payments and Creator payouts;
• account registration and authentication;
• strategy calls and consultations;
• enquiries and customer support;
• email and other communications;
• newsletters and marketing communications;
• promotions and campaigns;
• analytics and website technologies;
• AI-powered features, assistants and chat systems;
• social media interactions with UGC Era;
• fraud prevention, account verification and marketplace safety;
• UGC Era services provided to Brands and Creators; and
• other interactions with UGC Era.

This Privacy Policy does not govern independent third-party websites or services which may be linked from UGC Era.

3. Personal Information We May Collect#

The information we collect depends upon how you interact with UGC Era.

3.1 Account and Identity Information#

This may include:

• first and last name;
• username;
• email address;
• telephone number;
• account type;
• password or encrypted authentication credentials;
• profile photograph;
• country or region;
• language;
• age or date-of-birth information where required;
• business or Creator name;
• account identifiers; and
• account verification information.

Passwords should be stored using appropriate cryptographic protection. We do not intentionally make users' passwords visible to other marketplace users.

4. Creator Information#

If you register, apply or participate as a UGC Creator, we may collect information including:

• Creator name;
• profile photograph;
• videos, photographs and portfolio materials;
• biography;
• social media usernames and profile links;
• portfolio links;
• website;
• niches and content categories;
• languages;
• country, region or general location;
• Creator experience;
• skills;
• rates or pricing;
• availability;
• previous work;
• campaign preferences;
• audience or platform information where supplied;
• Creator applications;
• applications or responses to Brand briefs;
• ratings, reviews and marketplace history;
• messages and communications;
• content submissions;
• usage-rights information;
• payment and payout information;
• tax information where legally required; and
• identity, eligibility or verification information where reasonably required.

Certain information that Creators choose to place on a public Creator profile may be visible to Brands, website visitors and search engines.

Creators should not upload private information to public profile fields that they do not want made publicly available.

5. Brand and Business Information#

When a Brand, agency or business uses UGC Era, we may collect:

• contact names;
• business email addresses;
• telephone numbers;
• company name;
• company website;
• billing information;
• business address;
• campaign objectives;
• audience information;
• campaign briefs;
• product information;
• Creator requirements;
• creative requirements;
• messages with Creators or UGC Era;
• order and transaction information;
• support requests;
• advertising and performance information supplied to us;
• social media or advertising platform information; and
• other information necessary to deliver the requested service.

6. Payment and Financial Information#

Where paid services, marketplace transactions or Creator payouts are enabled, payment processing may be performed by specialist third-party payment providers such as Stripe or another authorised payment provider.

Where payment information is entered directly into a payment provider's secure interface, UGC Era generally does not receive or store complete debit or credit card numbers.

We may receive transaction-related information such as:

• payment status;
• payment amount;
• currency;
• transaction identifier;
• payer or recipient details;
• limited payment-method information;
• refunds;
• disputes;
• chargebacks;
• Creator payout status; and
• information required for accounting, fraud prevention or regulatory purposes.

Payment providers process information in accordance with their own privacy policies and regulatory obligations.

7. Communications and Support Information#

If you communicate with us, we may process:

• emails;
• contact-form submissions;
• customer-service enquiries;
• support messages;
• marketplace messages;
• complaints;
• call notes;
• meeting information;
• correspondence;
• feedback; and
• information that you voluntarily provide.

We may retain communications where reasonably necessary to provide support, resolve disputes, protect marketplace users, enforce agreements or establish, exercise or defend legal claims.

8. Technical and Usage Information#

When you use UGC Era, we or our authorised service providers may collect technical information such as:

• IP address;
• approximate geographic location derived from IP address;
• browser type;
• browser version;
• device type;
• operating system;
• referral URL;
• pages visited;
• session information;
• date and time of access;
• website interactions;
• account activity;
• authentication logs;
• error logs;
• security events;
• cookie identifiers;
• analytics identifiers; and
• similar technical information.

We use this information for purposes including security, fraud prevention, website operation, analytics and improving our services.

Non-essential analytics, advertising or tracking technologies will be used subject to applicable consent requirements.

9. Information Obtained From Other Sources#

We may lawfully obtain information from third parties or publicly available sources including:

• social media platforms;
• Creator portfolios;
• business websites;
• publicly available professional profiles;
• business directories;
• Brands;
• Creators;
• agencies;
• payment providers;
• analytics providers;
• fraud-prevention providers;
• authentication services;
• referral partners; and
• service providers.

For example, UGC Era may identify potential Creators through publicly available professional or social-media profiles.

The fact that contact information is publicly available does not automatically mean that the individual has consented to receive electronic marketing. UGC Era will apply applicable data protection and electronic-marketing rules when conducting outreach.

Where privacy law requires us to notify a person when we obtain their personal information indirectly, we will provide the required information within the applicable legal period unless an exemption applies.

10. Information You Provide About Other People#

You must only provide UGC Era with another person's personal information where you have the lawful right to do so.

For example, Brands must ensure that campaign data, testimonials, customer materials, photographs, audience lists or other materials provided to UGC Era have been collected and shared lawfully.

Creators must similarly ensure that people appearing in submitted content have provided any permissions or releases required by applicable law or the relevant project terms.

You must not knowingly upload unlawfully obtained personal information.

Where appropriate, responsibility for obtaining applicable notices, permissions or consent remains with the party that originally collected and provided the information.

11. Why We Use Personal Information#

We may process personal information for the following purposes.

Providing the UGC Era Service#

To:

• create and administer accounts;
• provide the marketplace;
• process Creator applications;
• display Creator profiles;
• allow Brands to discover Creators;
• publish and manage campaign briefs;
• facilitate Creator and Brand interactions;
• deliver agency services;
• administer campaigns;
• provide content-production services;
• manage projects;
• facilitate payments;
• facilitate Creator payouts;
• provide customer support;
• send service communications; and
• fulfil contracts.

Lawful basis: performance of a contract or taking steps at your request before entering into a contract.

Creator Discovery and Matching#

We may analyse Creator profile information, skills, portfolio, location, language, niche, experience, campaign preferences and other relevant factors in order to recommend or shortlist Creators for suitable campaigns.

Lawful basis: performance of a contract and/or our legitimate interests in operating an effective Creator marketplace and matching service.

Operating Public Creator Profiles#

Where a Creator chooses to publish a marketplace profile, certain profile information may be accessible by website visitors, Brands and search engines.

Lawful basis: performance of the Creator marketplace service and/or our legitimate interests in operating a searchable Creator marketplace.

Creators should carefully choose what information they publish.

Payments and Accounting#

We process transaction information to:

• receive payments;
• make Creator payouts;
• issue invoices;
• process refunds;
• deal with chargebacks;
• maintain financial records;
• calculate amounts owed; and
• comply with accounting, tax and regulatory requirements.

Lawful basis: contract, legal obligation and legitimate interests.

Security and Fraud Prevention#

We may process information to:

• protect accounts;
• detect suspicious activity;
• investigate fraud;
• prevent payment abuse;
• detect fake accounts;
• enforce marketplace rules;
• protect Brands and Creators;
• investigate complaints;
• prevent misuse of UGC Era; and
• protect our legal rights.

Lawful basis: legitimate interests, compliance with legal obligations and, where applicable, establishment, exercise or defence of legal claims.

Communications and Customer Support#

We process information to respond to enquiries and provide account, project and marketplace support.

Lawful basis: contract, steps taken before entering into a contract and/or legitimate interests.

Improving UGC Era#

We may use appropriate usage information to:

• improve the website;
• improve marketplace functionality;
• understand how services are used;
• diagnose technical problems;
• improve Creator recommendations;
• improve customer service;
• develop new functionality; and
• measure service performance.

Lawful basis: legitimate interests, except where consent is legally required for the technology involved.

Marketing#

Subject to applicable law, we may use contact information to tell users about:

• UGC Era services;
• relevant Creator opportunities;
• marketplace developments;
• new features;
• relevant campaigns;
• promotions;
• newsletters; and
• related services.

Where consent is legally required, we rely on consent.

Where law permits marketing on another basis, such as legitimate interests or an applicable business-to-business rule, we may rely on that basis subject to your rights and applicable electronic-marketing laws.

You can opt out of marketing at any time.

Legal and Regulatory Compliance#

We may use personal information to:

• comply with law;
• comply with regulatory requirements;
• respond to lawful government or court requests;
• maintain statutory records;
• investigate complaints;
• protect legal rights;
• enforce contracts; and
• establish, exercise or defend legal claims.

Lawful basis: legal obligation and/or legitimate interests.

12. Legitimate Interests#

Where we rely on legitimate interests, we consider whether the processing is necessary for a genuine business purpose and balance those interests against the rights and freedoms of affected individuals.

Our legitimate interests may include:

• operating and improving UGC Era;
• running a secure marketplace;
• preventing fraud and abuse;
• helping Brands identify appropriate Creators;
• providing customer support;
• maintaining business records;
• protecting users;
• protecting UGC Era's legal rights;
• measuring business performance;
• developing our services; and
• appropriate business-to-business marketing.

Where your interests or fundamental rights override our legitimate interests, we will not rely on that basis.

13. Consent#

Where we rely upon consent, you may withdraw your consent at any time.

Withdrawal does not affect processing that was lawfully carried out before consent was withdrawn.

Consent may be used for matters including:

• certain marketing communications;
• non-essential cookies;
• advertising or tracking technology;
• optional account features; or
• other processing where applicable law requires consent.

We will not treat silence, inactivity or a pre-ticked box as valid consent where affirmative consent is required.

14. Special Category and Sensitive Information#

UGC Era does not require users to provide unnecessary sensitive information.

Certain Creator content, communications or campaign requirements may nevertheless reveal information that receives enhanced legal protection.

Depending on applicable law, this may include information concerning:

• racial or ethnic origin;
• religious or philosophical beliefs;
• political opinions;
• trade union membership;
• health;
• sexual orientation or sex life;
• genetic information; or
• biometric information used for identification.

We will only intentionally process legally protected sensitive information where there is an appropriate lawful basis and, where required, an additional legal condition such as explicit consent.

We do not intend to infer sensitive characteristics from a person's image, name or content for unrelated purposes.

Users should avoid sending sensitive personal information to UGC Era unless it is genuinely necessary.

15. Identity, Eligibility and Safety Checks#

Where reasonably necessary and lawful, UGC Era may conduct or facilitate checks designed to verify:

• identity;
• age;
• account authenticity;
• payment information;
• Creator eligibility;
• business identity;
• fraud risk; or
• compliance with marketplace requirements.

Where a particular campaign or legal obligation requires additional screening, we will process that information only where we have a lawful basis to do so.

Criminal offence information or similarly protected information will only be processed where applicable law specifically permits it and appropriate safeguards are in place.

16. AI, Automated Tools and Creator Matching#

UGC Era may use artificial intelligence, algorithms or other automated technology to assist with activities such as:

• customer support;
• marketplace search;
• Creator recommendations;
• categorisation;
• fraud detection;
• content moderation;
• analytics;
• campaign administration;
• matching Creators with Brands; and
• improving services.

Automated tools may consider factors such as Creator category, location, language, portfolio characteristics, experience, availability and campaign requirements.

Where applicable law gives you rights relating to a decision made solely by automated processing which produces legal or similarly significant effects, those rights will be respected.

Where required, safeguards may include:

• meaningful human review;
• the ability to express your point of view;
• the ability to contest a decision; and
• information about relevant automated processing.

UGC Era does not intend to make significant solely automated decisions using specially protected personal information unless expressly permitted by law and appropriate safeguards are in place.

17. UGC Era AI and Chat Features#

Where UGC Era provides an AI assistant, chatbot or other automated support tool, information entered into that service may be processed to:

• respond to your enquiry;
• provide customer support;
• assist navigation;
• help with marketplace enquiries;
• improve support quality;
• prevent abuse; and
• maintain service security.

You should not enter passwords, complete payment-card information, highly sensitive personal information, confidential third-party information or information you do not have permission to disclose into an AI chat interface.

Where third-party AI infrastructure is used, the relevant provider may process data on our behalf subject to contractual and data-protection safeguards.

UGC Era will not intentionally use customer or Creator confidential information to train publicly available artificial-intelligence models unless this has been clearly disclosed and there is a lawful basis to do so.

18. Cookies and Similar Technologies#

UGC Era may use cookies, pixels, local storage and similar technologies.

These may include:

Strictly Necessary Technologies

Required to:

• operate the website;
• maintain sessions;
• authenticate accounts;
• provide security;
• remember essential settings; and
• process transactions.

These may not require consent where legally exempt.

Functional Technologies

Used to remember choices and provide enhanced functionality.

Analytics Technologies

Used to understand website use and improve performance.

Advertising Technologies

Where used, these may help measure advertising effectiveness or provide more relevant advertising.

Where applicable law requires consent, non-essential cookies and similar technologies will not be activated until the user has made an appropriate consent choice.

Users must be able to reject or manage non-essential cookies as required by applicable law.

More detailed information should be provided in our Cookie Policy and cookie-preference interface.

19. Marketing Communications#

You can stop receiving direct marketing from us at any time by:

• using the unsubscribe mechanism in a marketing message;
• changing applicable communication preferences; or
• contacting us at hi@ugcera.com.

Transactional or service messages relating to an account, payment, marketplace transaction, security matter or contract are not necessarily marketing and may continue where reasonably necessary.

We maintain appropriate suppression records so that we can respect marketing opt-outs.

20. Who We Share Information With#

We do not disclose personal information indiscriminately.

We may share information with the following categories of recipient where necessary and lawful.

Brands and Creators#

Information may be shared between Brands and Creators where necessary to:

• operate the marketplace;
• consider Creator applications;
• arrange projects;
• manage briefs;
• deliver content;
• facilitate payments; and
• resolve project issues.

Only information reasonably relevant to the interaction should be shared.

Service Providers#

We may use carefully selected providers for services including:

• website hosting;
• cloud infrastructure;
• database services;
• email;
• customer support;
• analytics;
• cybersecurity;
• payment processing;
• Creator payouts;
• accounting;
• CRM systems;
• communications;
• identity verification;
• fraud prevention;
• AI infrastructure;
• content storage;
• file delivery; and
• professional services.

Where a provider processes personal information on our behalf, we require appropriate data-protection and confidentiality arrangements where required by law.

Professional Advisers#

Information may be shared where appropriate with:

• lawyers;
• accountants;
• insurers;
• auditors;
• tax advisers; and
• other professional advisers.

Authorities and Legal Proceedings#

We may disclose information where reasonably necessary to:

• comply with law;
• comply with a court order;
• respond to a lawful request;
• cooperate with regulators;
• investigate suspected fraud;
• prevent or investigate criminal activity;
• protect users;
• protect UGC Era; or
• establish, exercise or defend legal claims.

We will not voluntarily provide information to authorities merely because it has been requested informally where applicable law requires a valid legal basis.

Business Transfers#

If UGC Era is involved in a merger, financing, acquisition, restructuring, sale of assets or similar corporate transaction, personal information may be disclosed to appropriate advisers, prospective purchasers or transaction parties subject to appropriate confidentiality and legal safeguards.

21. Public Information#

Creator profiles and certain marketplace information may be intentionally public.

Information intentionally published to a public UGC Era profile may potentially:

• be viewed worldwide;
• appear in search engines;
• be copied or shared by third parties; and
• remain temporarily visible in search-engine caches after it is removed from UGC Era.

UGC Era cannot control independent copies lawfully made by third parties or search-engine caching outside our reasonable control.

Creators should therefore avoid publishing information they wish to keep private.

22. International Data Transfers#

UGC Era operates internationally and may use service providers located in different countries.

Personal information may therefore be transferred outside the United Kingdom or the country in which you live.

When applicable privacy law restricts international transfers, we use an appropriate legal transfer mechanism.

For UK personal information, this may include:

• UK adequacy regulations;
• the UK International Data Transfer Agreement ("IDTA");
• the UK International Data Transfer Addendum;
• another legally approved safeguard; or
• another lawful transfer mechanism.

Where required, we assess whether transferred information will receive an appropriate standard of protection and implement additional contractual, organisational or technical safeguards where necessary.

For information subject to the EU GDPR, appropriate safeguards may include an adequacy decision, Standard Contractual Clauses or another mechanism permitted by EU law.

23. How Long We Keep Personal Information#

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including legal, accounting, security and dispute-resolution requirements.

Retention periods may vary depending upon the type of information.

As a general framework:

Account Information

Normally retained while an account remains active and for a reasonable period afterwards where required for legal, fraud-prevention or record-keeping purposes.

Contracts, Orders and Transaction Records

May normally be retained for up to six years after the relevant relationship or transaction ends, or longer where law requires.

Financial and Tax Records

Retained for the period required by applicable accounting and tax laws.

Creator Campaign Records

Normally retained for the duration of the relationship plus an appropriate period afterwards for contractual, accounting, intellectual-property, usage-rights or dispute purposes.

Customer-Support Communications

Retained for as long as reasonably necessary to manage the matter and any related legal or business requirements.

Marketing Information

Retained until you opt out or the information is no longer required. Limited suppression information may be retained afterwards so that we can respect your opt-out.

Security and Fraud Information

May be retained where necessary to prevent repeated abuse, investigate incidents or protect our marketplace.

Cookie Information

Retention varies by technology and will be described in our Cookie Policy or consent management interface where appropriate.

At the end of the applicable retention period, information will be deleted, anonymised or otherwise securely disposed of unless continued retention is lawful and necessary.

24. Account Deletion#

Where account-deletion functionality is available, you may request deletion of your account.

Deleting an account does not necessarily require us to delete every associated record immediately.

We may retain information where required or permitted for purposes including:

• outstanding payments;
• Creator payouts;
• fraud prevention;
• tax or accounting requirements;
• legal compliance;
• dispute resolution;
• enforcement of agreements;
• chargebacks;
• security;
• legal claims; or
• exercising or defending legal rights.

Where information no longer needs to identify you, we may anonymise it instead.

25. Data Security#

UGC Era takes reasonable and proportionate technical and organisational measures designed to protect personal information from:

• unauthorised access;
• unlawful disclosure;
• accidental loss;
• destruction;
• alteration; and
• misuse.

Measures may include, where appropriate:

• encryption;
• access controls;
• password protection;
• secure hosting;
• account authentication;
• backups;
• logging;
• monitoring;
• staff or contractor access restrictions;
• service-provider due diligence; and
• incident-response procedures.

However, no website, internet transmission, electronic storage system or security system can be guaranteed to be completely secure.

Users are responsible for keeping their account credentials confidential and should notify UGC Era promptly if they believe an account has been compromised.

26. Personal Data Breaches#

Where a personal-data breach occurs, UGC Era will assess the incident and take appropriate action.

Where applicable law requires notification to a regulator or affected individuals, we will make the relevant notification within the legally required period.

We may take steps including:

• containing the incident;
• investigating what happened;
• assessing risk;
• securing affected systems;
• notifying relevant parties where legally required; and
• implementing measures designed to prevent recurrence.

27. Your Privacy Rights#

Depending on your location and applicable law, you may have rights including:

Right of Access

To request information about personal data we hold about you and obtain a copy.

Right to Rectification

To ask us to correct inaccurate or incomplete personal information.

Right to Erasure

To request deletion of personal information in certain circumstances.

This is not an absolute right and information may sometimes lawfully be retained.

Right to Restriction

To request that processing be restricted in certain circumstances.

Right to Object

To object to processing based on legitimate interests in certain circumstances.

You have an absolute right to object to certain direct marketing.

Right to Data Portability

To receive certain information in a structured, commonly used and machine-readable format where the legal requirements apply.

Right to Withdraw Consent

Where processing is based upon consent, you can withdraw it at any time.

Rights Concerning Automated Decisions

Where applicable, you may have rights concerning certain solely automated decisions that produce legal or similarly significant effects.

Right to Complain

You may make a data protection complaint directly to UGC Era and may also have the right to complain to the relevant supervisory authority.

Rights are subject to applicable statutory conditions and exemptions.

28. Exercising Your Rights#

Requests can be sent to:

hi@ugcera.com

Please use the subject:

Privacy Request

We may ask for information reasonably necessary to confirm your identity before fulfilling certain requests.

We will not request unnecessary identity documentation.

We aim to respond within the period required by applicable law.

Where permitted by law, the response period may be extended for particularly complex or numerous requests. If this happens, we will inform you as required.

Ordinarily, there is no fee for exercising privacy rights. However, applicable law may allow us to charge a reasonable fee or refuse a request where it is manifestly unfounded or excessive.

29. Data Protection Complaints#

If you believe UGC Era has not handled your personal information correctly, you can make a data protection complaint by emailing:

hi@ugcera.com

Subject:

Data Protection Complaint

Your complaint should include enough information for us to understand the issue.

In accordance with applicable UK data protection requirements, UGC Era will:

• provide an accessible way for people to raise data protection complaints;
• acknowledge qualifying complaints within the legally required period;
• take appropriate steps to investigate the complaint;
• keep the complainant appropriately informed; and
• communicate the outcome without undue delay.

For UK complaints, the current statutory framework requires qualifying data protection complaints to be acknowledged within 30 days.

You may also have the right to complain to the UK's data protection regulator:

Information Commissioner's Office (ICO)

You are not required to surrender your legal right to complain to a regulator.

We encourage individuals to contact UGC Era first where appropriate so that we have an opportunity to investigate and resolve the issue.

30. European Economic Area Users#

Where UGC Era's processing is subject to the EU GDPR, users within the European Economic Area may exercise applicable EU GDPR rights and may complain to a competent data-protection supervisory authority.

Where EU law requires UGC Era to appoint an EU representative, the relevant representative's details will be published in this Privacy Policy or otherwise made readily available.

31. United States Privacy Rights#

Residents of certain U.S. states may have additional privacy rights where the relevant state privacy legislation applies to UGC Era.

Depending upon the applicable law and whether relevant statutory thresholds are met, these may include rights to:

• know or access personal information;
• correct inaccurate information;
• delete certain personal information;
• obtain a portable copy;
• opt out of certain targeted advertising;
• opt out of certain sales or sharing of personal information;
• limit particular uses of sensitive personal information; and
• appeal certain privacy decisions.

UGC Era does not sell personal information for money.

However, certain uses of third-party advertising or analytics technologies may be legally characterised as "selling", "sharing" or targeted advertising under some U.S. privacy laws even where no money is exchanged.

Where applicable law requires an opt-out mechanism for such activity, UGC Era will provide an appropriate privacy-choice mechanism.

Where required by law and technically supported, we will recognise applicable legally valid browser-based opt-out preference signals.

We do not knowingly sell or share personal information belonging to children in circumstances prohibited by applicable law.

32. Children#

UGC Era's standard commercial marketplace and business services are intended for adults.

Users must meet the minimum age stated in our Terms & Conditions and any applicable Creator eligibility requirements.

We do not knowingly collect personal information from children in circumstances prohibited by applicable law.

If we discover that personal information has been collected from a child unlawfully, we will take appropriate steps to delete or otherwise lawfully address the information.

If you believe a child has provided personal information to us contrary to this policy, contact:

hi@ugcera.com

33. Social Media and Third-Party Platforms#

UGC Era may maintain profiles or interact with users through platforms including TikTok, Instagram, Facebook, YouTube, LinkedIn and other services.

Those platforms independently determine how they process much of the information provided to them.

Your use of those services is subject to the privacy practices of the relevant platform.

UGC Era is not responsible for independent processing carried out by third-party platforms outside our control.

34. External Websites#

UGC Era may contain links to websites, tools or services operated by third parties.

Following an external link does not mean that UGC Era controls or endorses that third party's privacy practices.

We encourage users to review the privacy policies of third-party services before providing personal information.

35. Business Customers Acting as Controllers#

Where a Brand or business provides personal information to UGC Era for processing as part of a campaign or service, that business may be responsible for determining whether it has an appropriate lawful basis to collect and disclose that information.

The business customer is responsible for providing any privacy notices or obtaining any permissions required by law for information which it controls.

Where UGC Era acts purely as a processor, we will process personal information in accordance with the relevant contract, documented instructions and applicable data-protection law.

36. Anonymised and Aggregated Information#

We may create statistics, insights or aggregated information which no longer identifies an individual.

Properly anonymised information is not personal information.

We may use anonymised or aggregated information for purposes including:

• analytics;
• reporting;
• marketplace statistics;
• service improvement;
• research;
• benchmarking; and
• business planning.

We will not intentionally attempt to re-identify information that has been properly anonymised unless legally permitted and necessary for security or validation purposes.

37. Legal Claims and Enforcement#

Nothing in this Privacy Policy prevents UGC Era from processing or retaining information where reasonably necessary to:

• protect UGC Era;
• protect Brands or Creators;
• investigate suspected wrongdoing;
• enforce contractual rights;
• recover money owed;
• defend against claims;
• bring legal proceedings;
• comply with court orders;
• preserve evidence; or
• establish, exercise or defend legal rights.

Such processing will only take place where there is a lawful basis.

38. Changes to Ownership or Structure#

If UGC Era changes its legal structure, ownership or business organisation, personal information may form part of the relevant business assets.

Any new controller will remain subject to applicable data-protection obligations.

Where applicable law requires notification of a material change, users will be notified appropriately.

39. Changes to This Privacy Policy#

We may update this Privacy Policy to reflect:

• changes to UGC Era;
• new marketplace functionality;
• new technology;
• legal or regulatory changes;
• changes to service providers; or
• changes to our processing activities.

The most recent version will be published on ugcera.com with its updated date.

Where a change materially affects how we use personal information, we will provide additional notice where required by law.

We encourage users to review this Privacy Policy periodically.

40. Contact UGC Era#

Questions about this Privacy Policy, your personal information or your privacy rights can be sent to:

UGC Era

Website: ugcera.com

Email: hi@ugcera.com

Privacy requests: hi@ugcera.com

Data protection complaints: hi@ugcera.com

Business/legal name: UGC Era

© 2026 UGC Era. All rights reserved.