Privacy Policy

Effective date: October 16, 2025

‍WGY Academy Limited (“WGY Ltd”) Privacy Policy

WGY Ltd respects your privacy and are committed to protecting your personal data. This privacy policy (“Privacy Policy”) explains how WGY Ltd (“we,” “us,” and/or “our”) collects, uses, and discloses information from individuals and organisations (“you” and/or “your”) who access and use our online community or mobile or other downloadable applications (collectively, the “Community”). 

How we collect your personal data 

We can collect personal data either automatically through the Community, directly from yourself, brands or third-party social media sites. 

This can be through voluntary information supplied by you, filling out a form, participating on our online platforms, interactions within the Community, making a purchase, publishing a statement on our platform, participating in a contest or promotion, social media sites and information from messages between members.

We and our third-party partners may automatically collect information you provide to us, information about how you access and use the Community and information about the device you use to access the Community. Including, device identifiers, internet or other electronic network activity information, geolocation information and information from cookies and similar technologies.

 

What personal data we collect

We will collect, store and use the following categories of personal data about you:

 

• Identity and contact data: full name, address, phone number, email address and any other information provided upon engaging with us

 

• Brand opportunity data: campaign information and company information related to opportunities 

 

• Biographic and demographic data: including biographic information you provide,and demographic statistics obtained through social media sites 

 

• Information from interactive features: supplied by you whilst participating in any interactive features of the Community 

 

• Messages between members: messages and information about those messages such as when a message was sent or received

 

• Content and information shared through the Community: such as comments on a blog post and participation information through interaction on the Community

 

• Payment data: If a payment is made through the Community, payment-related information, credit card and financial information shared. If payment is agreed to be made to you, billing information provided by you

 

• Device identifiers: such as your IP address, internet service provider, type of mobile device being used, the temporary or persistent unique device identifiers (sometimes called UDID), and identifiers associated with browser cookies, web beacons and similar technologies we deploy on the Community

 

• Electronic network activity information: including devices and computers you use to access the Community, browser type, language, operating system, referring web page, pages visited, and hyperlinks clicked 

 

• Internet activity information: including pages you visit, links you click, ads you view and click on, videos you watch, purchase information, checkout process and location when you access or interact with our Community 

 

• Geological information: the approximate location of your device from your IP address. We may combine this information with other location-based information, such as your billing or postal code. However, you can stop the collection of this information any time through your device’s operating system settings.

 

• Information from cookies and similar technologies: collected by us and our third-party partners including analytics. Our partners may use technologies to collect information about online activities over time and across different services. 

 

• Information from third-party sources: such as marketing partners and others that you choose to share or provide to them when interacting with our members in the Community.

 

Legal basis for processing your data

We process your personal data in accordance with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018. The legal basis we rely on are: 

• Performance of a contract: we process your personal data where it is necessary for the fulfilment of our contractual obligations. For example, to connect brand opportunities with content creators, manage contractual payments and communicate information on campaigns and opportunities 

 

• Legitimate interests: we process certain personal data where it is necessary for our legitimate interests unless there is good reason to protect your personal data which overrides our legitimate interests. These interests include improving our services, responding to any enquiries or complaints, building and maintaining a network for brand and influencer opportunities and promotional activities. 

 

• Consent: we can process personal data where we have obtained your consent. For example, if we communicate a collaborative opportunity and request details to be shared from you with a brand 

 

• Legal obligations: we will process your personal data where it becomes necessary for us to comply with the law. For example, with our regulatory requirements, legal proceedings or order from a court.

 

Data sharing 

In certain circumstances, we need to share your personal data with other third parties, including partners and service providers. 

Any disclosures or data sharing will be done in accordance with the law or relevant contractual arrangements. Third parties are required to take appropriate security measures to protect your personal data. We only permit them to process your personal data for specified purposes and in accordance with our instructions. They are not allowed to use your personal data for their own purposes.

If you are a brand, we may share your campaign opportunities with influencers. If you are an influencer, we may share your data with brands to allow collaborations on campaign opportunities. 

We will share your personal data with service providers (including contractors and designated agents) who carry out the following functions: IT, payment processors and marketing facilitators.

We may need to share your personal data with third parties as part of any merger, acquisition, sale or restructure of our business.

We may need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC, disclosures as part of proceedings or responding to regulatory bodies. 

Data security

We have implemented appropriate security measures to protect your personal information against accidental loss and unauthorised access, use, alteration or disclosure. 

We impose controls for access to employee data based on business requirements and in accordance with the relevant lawful bases for processing. Any party with access rights will only process your personal information in accordance with applicable data security policies and procedures, relevant employee obligations or third-party contractual terms. 

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

We will only retain your personal information in accordance with applicable laws, regulatory requirements or for as long as necessary to fulfil the purposes for which we collected it, as set out in our Data Retention Policy.

In some circumstances, you can ask us to delete your personal information. This is considered in the next section. 

Once you are no longer engaged in service with us, we will retain and securely destroy your personal information in accordance with our Data Retention Policy and any applicable legal requirements.

Your rights in relation to your personal information

You have the following rights under data protection laws:

• Request access to your personal information (commonly known as making a data subject access request). We will provide you with copies of your personal information and other information, such as where we got the information from and who we have shared it with. 

• Request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. 

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

• Request the transfer of your personal information to another party.

• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Updates to this policy

This privacy policy may be updated to reflect changes in law or data practices, as such we encourage for you to regularly check this page for any changes.

Questions or complaints

If you have any questions or concerns about this privacy notice or how we handle your personal information, or if you wish to exercise any of the rights it refers to, contact support@wegotyouagency.com, who oversee compliance with this privacy notice.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO). The ICO's contact details are as follows:

The ICO's address:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

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Circle App Privacy Policy | Effective Date 16/10/2025

This privacy policy (“Privacy Policy”) explains how WGY Creator App (“we,” “us,” and/or “our”) collects, uses, and discloses information from individuals (“you” and/or “your”) who access and use our online community or mobile or other downloadable applications (collectively, the “Community”). Beyond the Privacy Policy, your use of the Community is also subject to our Terms of Service.

We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases (for example if we plan to use your information in a way that materially differs from this Privacy Policy), we will provide you with additional notice (such as sending you a notification).

We encourage you to review the Privacy Policy whenever you access the Community or otherwise interact with us to stay informed about our information practices and the choices available to you.

Personal Information We Collect

Personal Information You Provide to Us.

Registration and Profile Information. When you open an account with us through the Community (“Account”), we may ask you to provide us with identifiers and contact information such as your name, email address, and any other information you may provide.

Communications. We may also collect identifiers, such as your name, email address, and other information you choose to provide, when you participate in any interactive features of the Community (like send us a message through the Community), fill out a form, publish statements on our platform, participate in a contest or promotion, communicate with us via third-party social media sites, request customer support, or otherwise communicate with us. Messages Between Members. When you communicate with other members through the Community, we and our third-party partners receive the content of the messages you send and receive and information about those messages, such as when it was sent or received.

Content. We may collect other content and information you share through the Community when you submit information or content, such as by commenting on a blog or participating in online communities, or when you otherwise interact with the Community.

Payment Information. If you make a purchase through the Community, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.

Personal Information That May Be Collected Automatically Through the Community.

When you access or use the Community or transact business with us, we and our third-party partners may automatically collect information you provide to us, information about how you access and use the Community and information about the device you use to access the Community, including:

Device Identifiers. Identifiers, such as your IP address, internet service provider, the type of mobile device you use, the temporary or persistent unique device identifiers (sometimes called UDID), and identifiers associated with browser cookies, web beacons and similar technologies we deploy on the Community.

Internet or Other Electronic Network Activity Information. We and our third-party partners may collect information about the devices and computers you use to access our Community, such as browser type, language, operating system, the referring web page, pages visited, and hyperlinks clicked. When you use our Community, we may collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Community and other information about your internet activity (“Usage Information”), including the pages you visit, the links you click, the ads you view and click on, videos you watch, purchase information and your checkout process, your location when you access or interact with our Community, and other similar actions. We may also use third-party tools to collect Usage Information you provide to us or information about how you use the Community and may record your mouse movements, scrolling, clicks and keystroke activity and other browsing, search or purchasing behavior. These tools may also record Usage Information you enter when you interact with the Community or engage in chat features through the Community.

Geolocation Information. We may derive the approximate location of your device from your IP address. We may combine this information with other location-based information, such as your billing or postal code. You have the ability to stop the collection of precise location information at any time (see “Your Choices” below for details).

Information From Cookies and Similar Technologies. We and our third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Community.

Please review your web browser’s “Help” file to learn how you may modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Community, you may not be able to utilize the features of the Community to their fullest potential.

Personal Information Collected from Third Parties.

Information from Third-Party Sources. When you interact with our members in the Community, we may collect from them any content or information you choose to share or provide. We may also obtain information about you from other sources, including but not limited to social media platforms, marketing partners, and other third parties. For example, if you connect your social media account to your Account or create or log into your Account through a social media site, certain information from your social media account will be shared with us, which may include information that is part of your profile or your friends’ profiles.

Personal Information Usage

We use the information we collect about you to:

  • provide, maintain, and improve the Community and to enhance and personalize your experience;
  • process, complete, and maintain records on transactions;
  • send you technical notices, updates, security alerts, and support and administrative messages;
  • respond to your comments, questions, and requests, and to provide customer service;
  • communicate with you about products, services, offers, promotions, rewards, and events offered by WGY Creator App and others, and provide news and information we think will be of interest to you;
  • monitor and analyze trends, usage, effectiveness and activities in connection with the Community, including our offers, advertising, communications features, and customer service;
  • detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of WGY Creator App;
  • facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
  • link or combine with information we get from the Community and from others to help understand your needs and provide you with better service;
  • maintain appropriate records for internal administrative purposes; and
  • carry out any other purpose described to you at the time the information was collected or permitted by law.

Personal Information Disclosure

Partners and Affiliates. We may disclose any information we receive to our partners, corporate affiliates, parents, or subsidiaries for any purpose described in this Privacy Policy.

Circle. The Community is powered by a technology platform provided by CircleCo, Inc. (“Circle”). We may disclose your information to Circle in connection with the provision of the Community.

Service Providers and Vendors. We may disclose your information to other vendors, consultants, and service providers retained in connection with the provision of the Community.

Other Members of the Community. If you provide or share information with other members of the Community, they may use it for their own purposes. If you post information or content, such as by posting photos, commenting on a blog, or participating in the Community, or when you interact with the Community through social media sites, plug-ins or other applications, depending upon your privacy settings, this information may become public on the internet. We cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.

Analytics Partners. We may use analytics services to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources.

Legal and Law Enforcement. We may share information collected about you with law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Community member to legal liability or if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

In Connection with a Change of Control. We may transfer or disclose your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.

Consent. Where applicable, we may share your information with your consent or at your specific direction.

Children’s Privacy

The Community is not intended for individuals under the age of 16. No one under the age of 16 is authorized to provide any personal information through the Community. We do not knowingly collect personal information from the Community from members in this age group. If we learn that we have collected or received personal information from a child under the age of 16, we will take reasonable steps to delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.

Social Sharing Features

The Community may offer social sharing features and other integrated tools, which let you share actions you take on the Community with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Third-Parties

The Community may contain links to other websites, including our affiliated or co-branded websites and communities. Other websites and communities may also reference or link to the Community. These other websites and communities may not be controlled by us. We encourage our members to read the privacy policies of every website, community, or mobile application that collects personal information. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of other websites, communities, or mobile applications. Visiting these other websites is at your own risk.

Security

We make reasonable efforts to protect your information by using security measures designed to safeguard the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Transfer of Information to the U.S. from Other Countries

The Community is hosted in the United States and intended for visitors located within the U.S. If you choose to use the Community from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Community. By providing any information, including personal information, on or to the Community, you consent to such transfer, storage, and processing.

Your Choices

Account Information. You may update and correct certain Account information you provide to us at any time by logging into your Account. If you wish to delete or deactivate your Account, you may email us at support@wegotyouagency.com but note that we may retain certain information as required by law or for legitimate business purposes.

Location Information. If you initially consent to our collection of this location information through the Community, you can subsequently stop the collection of this information at any time through your device’s operating system settings. If you do so, certain features may no longer function properly.

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Mobile Push Notifications/Alerts. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Contact Us

If you have any questions, comments or concerns about our/Circle’s Privacy Policy, you may email us at support@wegotyouagency.com.

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