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Crember - Privacy Policy

Effective Date: 7th Oct, 2026 | Last Updated: 7th Oct, 2026

About this privacy policy

Crember is a creator discovery and campaign tracking platform operated by the Crember Entity. Crember enables brands, agencies and other professional users to discover, research and evaluate relevant Creators and creator-related information for legitimate business, marketing, advertising and collaboration purposes.

Crember is designed around a selective, relevance-led approach to creator discovery rather than indiscriminate aggregation of every discoverable creator profile. Information available through Crember may originate from public-facing sources and third-party data services and may not always be independently verified, current or error-free.

This Policy applies to Personal Data processed by Crember Entity in connection with Crember, including information relating to Customers, Authorised Users, Creators, professional contacts, persons who communicate with us and other individuals whose information is relevant to the operation of the Platform.

This Policy does not govern the independent processing practices of social-media platforms, websites, Customers, Creators or other third parties.

Those parties may have separate terms, privacy policies and legal obligations.

Information we collect or receive

Depending on how Crember is used and the relevant processing activity, we may process:

  • (a)Account and business information, including name, work email, organisation, designation, login identifiers, subscription information and related account details.
  • (b)Creator-related information, including name, profile information, professional category, social-media identifiers, and other creator intelligence, where available.
  • (c)Information concerning public-facing Creator activity, such as publicly observable posts, profile information, mentions, engagement indicators, topics, hashtags, links and similar information, where lawfully accessible and relevant to Crember.
  • (d)Information supplied by Customers, including Creator lists, campaign briefs, and commercial information.
  • (e)Technical and usage information required for authentication, security, diagnostics, performance, analytics and administration.
  • (f)Information provided when a person contacts Crember Entity, submits a request, reports an issue or exercises a privacy, copyright or other legal right.
  • (g)Information generated or derived through Crember, including classifications, metrics, comparisons, trends, recommendations, scores, summaries and other analytical outputs.

How we obtain creator information

Crember may obtain or derive Creator-related information from several sources, depending on the relevant service and processing activity, including:

  • (a)publicly accessible websites, social-media profiles and other open sources;
  • (b)third-party APIs, applications, data providers, indexing services, aggregation services and other technology providers;
  • (c)information voluntarily provided to Crember Entity by Creators or their representatives, including in response to an enquiry, request or rights-related communication; and
  • (d)information generated, calculated or derived through Crember’s systems and methodologies.

Crember Entity may change, replace, restrict or discontinue a particular source where reasonably necessary because of legal requirements, contractual restrictions, source changes, technical limitations, security considerations, product requirements or operational considerations.

Publicly available information

Crember is designed to use information that is accessible through public-facing sources for creator-intelligence, research and related business purposes. The Crember Entity uses information only to the extent it considers appropriate for the relevant purpose and subject to applicable law and relevant source restrictions.

Where applicable and when in force, Crember Entity may rely on statutory provisions concerning Personal Data that has been made publicly available by the Data Principal or by another person who is under an obligation under applicable law to make such Personal Data publicly available, to the extent permitted under applicable law.

Crember Entity does not represent that every item of information available through Crember is free from third-party rights, nor that public availability removes all restrictions on subsequent processing or use.

Our selective creator-intelligence approach

Crember is intentionally designed around relevance rather than indiscriminate aggregation. Crember Entity may identify, include, update, suppress, restrict or remove Creator information based on relevance to the Platform, data quality, source availability, legal requirements, rights requests, product methodology and other legitimate operational considerations.

The inclusion of a Creator does not constitute an endorsement, verification of character, guarantee of suitability, representation of affiliation or assurance that the Creator will accept a commercial opportunity.

Creator intelligence may be incomplete or inaccurate. Crember Entity may use automated processes and human review where appropriate to improve data quality, but does not warrant that every Creator profile or analytical output is accurate, complete or current.

Why we process information

  • (a)provide, operate, administer and secure Crember;
  • (b)enable Creator search, discovery, research, evaluation and intelligence functionality;
  • (c)organise, analyse, classify and generate insights from Creator-related information;
  • (d)maintain and improve Platform quality, functionality, security and performance;
  • (e)manage accounts, subscriptions, billing, support and business relationships;
  • (f)detect and prevent fraud, abuse, unauthorised access, security incidents and misuse;
  • (g)respond to correction, suppression, deletion, objection, grievance and other rights requests;
  • (h)protect Crember Entity’s legal rights and interests and enforce the Terms;
  • (i)comply with applicable legal, regulatory or governmental requirements; and
  • (j)undertake other processing reasonably connected with the Services and permitted by applicable law.

How we lawfully process personal data

The Crember Entity processes information in accordance with applicable Indian law and for the purposes described in this Policy.

The basis on which information is processed may vary depending on the type of information, how it was obtained, why it is being used and the relationship between the Crember Entity and the relevant person.

Where applicable law requires consent, the Crember Entity will seek consent through appropriate means. Where applicable law permits processing without consent, the Crember Entity may process information on another lawful basis available to it.

The Crember Entity may use information available through public-facing sources for creator discovery, research, analysis and related business purposes where such use is permitted under applicable law. The Crember Entity does not represent that public availability by itself removes every legal or contractual restriction on subsequent use.

The Crember Entity may update its practices from time to time to reflect changes in applicable Indian law, regulatory requirements, technology, security standards and the operation of Crember.

Our role and customer responsibilities

The Crember Entity may process information for operating, securing, maintaining, improving and providing Crember and may also process information on behalf of Customers where the relevant arrangement and applicable law require it. The nature of the Crember Entity’s role may therefore vary according to the particular processing activity.

Where the Crember Entity processes Personal Data on a Customer’s behalf and in accordance with the Customer’s instructions, the Customer remains responsible for determining the purposes and ensuring that its instructions and use of the Platform are lawful.

The Crember Entity does not make a blanket representation as to its legal role for every category of information or every processing activity. The applicable role and responsibilities will depend on the actual nature and purpose of the relevant processing and the requirements of applicable law.

A Customer remains responsible for processing that it independently undertakes after obtaining information through Crember, including where it contacts a Creator, imports information into another system, combines it with other information, sends communications, conducts a campaign or otherwise determines a new purpose for processing.

Customers are responsible for ensuring that they have the necessary authority and lawful basis for Personal Data they provide to Crember and for subsequent processing undertaken by them. Crember’s provision of Creator information does not constitute a representation that the Customer has consent or another lawful basis for every subsequent use.

Social intelligence and social-listening-type processing

Crember may organise, analyse and present publicly observable social-media signals for creator-intelligence and business-research purposes. This may include publicly visible mentions, references to brands or topics, hashtags, engagement indicators, content themes and similar signals.

Such functionality may be referred to as “social intelligence”, “social listening” or similar terminology. These terms describe the organisation and analysis of observable signals and do not mean that Crember Entity accesses private messages, closed groups, restricted accounts or other communications that are not lawfully accessible to it.

Information used for such functionality may be obtained directly or indirectly through public-facing sources, APIs, third-party applications, data providers, indexing services, aggregation services or other technology providers. Crember Entity may therefore receive information that is incomplete, stale, duplicated, incorrectly formatted or otherwise inaccurate.

Crember Entity may process publicly observable social-media signals where such processing is permitted under applicable law and is relevant to the purposes described in this Policy.

References to social intelligence or social-listening-type functionality describe the nature of certain analytical functions and sources that may be used in the Platform.

Where a third-party source or provider independently determines the purposes and means of its own processing, that processing is governed by the provider’s own terms and privacy policy. Crember Entity does not control independent processing carried out outside its reasonable control.

Creator correction, suppression and opt-out

A Creator may contact Crember Entity to request correction or suppression of Creator information, subject to applicable law.

Where a Creator requests that information about them no longer be made available through Crember, Crember Entity may, where appropriate, suppress the relevant profile or fields from search or display, remove or restrict contact information, or take other technically reasonable steps to prevent continued display or reintroduction.

Suppression from Crember does not necessarily remove the information from the original social-media platform, website or other independent third-party source from which it was obtained. Crember Entity does not control those independent sources.

Crember Entity may retain limited records necessary to document a suppression request, prevent repeated reintroduction, comply with law, protect legal rights or maintain security.

Children and persons under 18

Crember is intended for business and professional use and is not directed at persons below eighteen (18) years of age. Crember does not provide a Creator registration or onboarding facility.

Because information available through public or third-party sources may relate to persons of different ages, information concerning a person below eighteen (18) years of age may nevertheless appear in source information. Such incidental appearance does not mean that Crember invited that person to use the Platform or collected the information directly from them.

A person below eighteen (18) years of age, or their parent or lawful guardian, may request suppression or removal of relevant information through the privacy contact identified below. Crember Entity may prioritise such requests and may take reasonable interim steps while verification is completed.

The Crember Entity will apply the safeguards required by applicable Indian law where information relating to persons below eighteen (18) years of age is processed.

Crember Entity does not knowingly use Crember to target persons below eighteen (18) years of age for advertising or commercial solicitation.

Automated processing, analytics and profiling

Crember may use automated systems, artificial intelligence and analytical tools to organise, classify, summarise, compare or generate insights from information processed through the Platform.

Examples may include categorising Creators by professional relevance, analysing audience or engagement indicators, identifying topics or brand references, generating recommendations, or prioritising search results.

Automated outputs may be probabilistic and may contain errors. They are intended to support business research and decision-making and should not be treated as verified facts or as a determination of an individual’s character, suitability, trustworthiness or entitlement to an opportunity.

Crember Entity may use human review, correction, suppression or other controls where reasonably appropriate. Crember Entity may restrict functionality or Customer access where it reasonably considers that use could facilitate unlawful discrimination, harassment, prohibited profiling or other unlawful activity.

Sensitive information

Crember is not designed to intentionally seek unnecessary sensitive or special-category personal information for ordinary Creator discovery. Where information that may constitute sensitive or special-category information is publicly disclosed or otherwise received through a lawful source, Crember Entity will process it only to the extent permitted by applicable law and relevant to the processing purpose.

Creator profiles and source materials may contain photographs, videos, reels, music, sound recordings, graphics, text, logos and other creative works owned or controlled by third parties.

The availability of a reference, link, profile identifier, thumbnail, excerpt or other information through Crember does not by itself grant a Customer ownership of, or a licence to commercially exploit, the underlying creative work.

Crember Entity does not represent that it owns all rights in third-party content merely because information relating to that content is available through Crember.

Customers are responsible for obtaining all permissions, licences, releases or other rights required for their intended commercial use of third-party content.

Who we may share information with

  • (a)Service Providers supporting hosting, infrastructure, security, analytics, communications, information services, support and other Platform functions;
  • (b)Customers where necessary to provide requested Crember functionality;
  • (c)professional advisers and auditors where reasonably necessary;
  • (d)courts, regulators, law-enforcement authorities, governmental bodies or other persons where required or permitted by law; and
  • (e)other persons where authorised by the individual, Customer or applicable law.

The Crember Entity does not make a Customer’s private campaign budgets, negotiated commercial terms or internal CRM notes available as part of the general Creator intelligence offering, except where necessary to comply with law, protect rights or as otherwise permitted by law.

Service providers and third-party processors

Crember Entity may appoint Service Providers to process information on its behalf. Crember Entity seeks to impose appropriate contractual and operational controls concerning confidentiality, security, permitted processing, access, retention and deletion, taking into account the nature of the relevant service.

Where a third-party provider independently processes information under its own terms, privacy policy or business purposes, that provider is responsible for its own processing. The Crember Entity does not control processing carried out independently by such third parties.

Processing through service providers

Crember Entity and its Service Providers may process or access information in jurisdictions other than the jurisdiction in which an individual is located.

Where applicable law imposes requirements concerning international transfers or access, Crember Entity will implement the safeguards required by that law.

Retention

Crember Entity retains Personal Data for no longer than reasonably necessary for the relevant processing purpose, contractual relationship, legal obligation, security requirement, dispute resolution or other permitted purpose.

Retention periods may differ by information category and processing purpose.

Crember Entity may retain limited records after deletion or suppression where necessary to comply with law, document rights requests, prevent fraud or reintroduction, maintain security, or establish or defend legal claims.

Security

Crember Entity maintains technical and organisational measures designed to protect Personal Data against unauthorised access, misuse, alteration, disclosure or destruction, having regard to the nature of the information and reasonably foreseeable risks.

No electronic system, database or transmission method can be guaranteed to be completely secure. Crember Entity therefore does not warrant absolute security.

Crember Entity maintains procedures for identifying, assessing, containing and responding to security incidents. Where notification is required by applicable law, Crember Entity will provide the required notification within the applicable timeframe and through the applicable channel.

Cookies and similar technologies

Crember may use cookies and similar technologies for authentication, session management, security, preferences, analytics and related functionality. Where applicable law requires consent or additional notice, appropriate notice and controls will be provided.

Your privacy rights

Depending on the applicable law and the circumstances of the processing, individuals may have rights relating to access, correction, deletion, withdrawal of consent, suppression, grievance redressal or other rights.

Crember Entity may require reasonable information to verify identity, authority and the scope of a request. Crember Entity may decline or limit a request where permitted or required by applicable law, including where retention or processing is necessary for legal compliance, security, fraud prevention, dispute resolution or establishment or defence of legal claims.

Privacy contact and grievance redressal

Privacy Contact / Grievance Officer:
Shivani Parashar, Legal Counsel

Requests concerning Creator information, correction, suppression, privacy rights or other privacy concerns may be submitted through the designated contact. Crember Entity may request reasonable information necessary to verify the request and determine the appropriate response.

Changes to this privacy policy

Crember Entity may update this Policy to reflect changes in Crember, technology, information sources, applicable law, security requirements, services or business practices. Where applicable law requires notice of a material change, Crember Entity will provide the required notice.

Governing law

This Privacy Policy shall be governed by and construed in accordance with the laws of India. Any dispute, controversy or claim arising out of or relating to this Privacy Policy, including its interpretation, implementation or the processing of Personal Data in connection with Crember, shall, to the extent legally permissible, be resolved by arbitration in accordance with the Arbitration and Conciliation Act, 1996, as amended from time to time. The arbitration shall be conducted by a sole arbitrator mutually appointed by the parties. The seat and legal place of arbitration shall be Gurugram, Haryana, India, and the arbitration proceedings shall be conducted in English. The arbitral award shall be final and binding on the parties. Subject to the foregoing arbitration agreement and any mandatory rights or remedies available under applicable law, the courts at Gurugram, Haryana shall have exclusive jurisdiction in relation to matters arising out of or connected with this Privacy Policy, including applications for interim or conservatory relief, appointment or replacement of the arbitrator, enforcement or challenge of an arbitral award, and any matter that is not capable of being referred to arbitration.