1. INTRODUCTION
1.1. This Policy describes how We processes personal data in connection with the operation of the Website, including the Management Platform, and the administration, evaluation, and payout of Campaigns conducted through Clipping Platforms operated by Clipping Platform Operators under the Campaign Participation Terms and related agreements.
1.2. This Policy applies to all data subjects whose personal data We processes as controller or joint controller, including representatives of Clients, Users; Clipping Platform Operators; and visitors to the Website or Management Platform.
1.3. This Policy does not apply to the independent privacy practices of, in particular, Clients, Clipping Platform Operators, Clipping Platforms, or Internet Media operators, each of which remains responsible for its own processing activities.
2. DEFINITIONS
2.1. Capitalized terms herein shall have the following meaning:
(a) “Campaigns” means campaigns and public competitions hosted on the Clipping Platforms under the CPTs.
(b) “User” means any User Content-supplying participant in Campaigns.
(c) “User Content” means content, including posts, videos, or other media, shared through Internet Media by Users and clipped on the Clipping Platform in connection with a Campaign.
(d) “Clipping Platform” means web, mobile, or application interface platform (such as Discord channels or proprietary platform) operated by Clipping Platform Operator enabling User participation in Campaigns.
(e) “Clipping Platform Operator” means an independent content aggregation partner operating a Clipping Platform for User participation in Campaigns.
(f) “Campaign Participation Terms” or “CPTs” mean Campaign Participation Terms, available through the Website.
(g) “Client” means the brand, agency, or other entity commissioning the Campaign.
(h) “Internet Media” means third-party internet media platforms (such as YouTube, TikTok, Instagram or similar) selected by Clients among those We approved for Campaign execution.
(i) “Management Platform” means Client-facing management platform for Campaign administration available at the Website.
(j) “Website” means https://evangelist.so.
(k) “We” (and similar) means Momentist, Inc.
3. ROLES OF THE MAIN PARTIES
3.1. We as Controller
We act as an independent controller for all personal data it processes in connection with: (a) operation of the Website and the Management Platform; (b) onboarding and verification of Users and Clipping Platform Operators; (c) organization and evaluation of Campaigns; (d) payout administration and authorization; and (e) analytics, compliance, audit, and reporting.
3.2. Clipping Platform Operators as Independent or Joint Controllers
Each Clipping Platform Operator independently operates a Clipping Platform and collects personal data from its Users under its own privacy policy. For processing directly related to Campaign participation, verification, and payout facilitation, We and the relevant Clipping Platform Operator act as joint controllers, as further described in CPTs.
3.3. Clients as Independent Controllers
Clients commissioning Campaigns act as independent controllers for personal data they receive in reports, analytics outputs or performance summaries from Us. We are authorised to show their privacy policies to Users, although we are not responsible for their compliance with data protection laws.
3.4. Service Vendors as Processors
Our service vendors act as a processor to Us for the limited purpose of facilitating payouts in crypto to certain Users and performing certain other operational, analytics or support functions under Our written instructions and subject to data-protection safeguards equivalent to those set out in this Policy.
Such processors include our affiliates, Customer.io (email automation), Segment.com (event analytics), Microsoft Azure App Insights (technical logging), Vouch (User data verification), Google Cloud and Microsoft Azure (video analysis and AI-based content processing).
4. CATEGORIES OF PERSONAL DATA
4.1. We process the following categories of personal data, depending on the individual’s relationship with Us:
| Category | Examples |
| Authentication and Scheduling Data | Name, Work email, verification token, timestamp, and associated IP/device metadata for the purpose of secure sign-in and fraud prevention. |
| Identifiers and Contact Data | Social media handles, usernames, profile links, email addresses, or payment service identifiers (e.g., PayPal address or crypto wallet). |
| Campaign and Performance Data | Participation records, engagement metrics, payout determinations, and performance stats and scores generated via Our evaluation software. |
| Account and Access Data | Login credentials, session tokens, device identifiers, and technical logs for access to the Website or Management Platform. |
| Financial and Payout Data | Payout amounts, currency, payment or crypto wallet identifiers, and transaction metadata. |
| Communications Data | Correspondence between Users, Clipping Platform Operators, and Us, including complaints and support inquiries. |
| Cookies and Usage Data | Data collected automatically through cookies and similar technologies as described in Clause 8.2 below. |
4.2. We do not require or intentionally collect or process sensitive personal data (such as government identifiers or biometric information) except where legally required for tax, sanctions, or identity-verification purposes. The Website, the Management Platform, and participation in Campaigns are intended solely for professional and business use by Clients, Clipping Platform Operators, and Users acting in a commercial or professional capacity. They are not directed to, or intended for use by, consumers or individuals under the age of eighteen (18) (or the age of majority in User’s jurisdiction). We do not knowingly collect or process personal data from minors or from individuals acting outside a professional context, and if We become aware that such data has been obtained, We will delete or anonymize it without undue delay in accordance with applicable law.
5. PURPOSES AND LEGAL BASES OF PROCESSING
5.1. We process personal data for the following purposes and on the corresponding lawful bases:
| Purpose of Processing | Legal Basis |
| Account access, authentication and onboarding coordination | Performance of contract (with the Client); legitimate interest in maintaining platform security. |
| Administration, evaluation, and fulfilment of Campaigns | Performance of a contract (CPT); legitimate interest in ensuring Campaign integrity |
| Account creation, onboarding, and verification of Users or Clipping Platform Operators | Performance of a contract; compliance with legal obligations |
| Execution and administration of payouts | Performance of a contract; legitimate interest; legal obligation for financial compliance |
| Analytics, performance measurement, and product improvement | Legitimate interest in improving services |
| Security, fraud prevention, and audit | Legitimate interest; legal obligation |
| Marketing communications and updates (limited B2B context) | Consent (where required); legitimate interest in business development |
| Compliance with legal or regulatory obligations | Legal obligation |
5.2. Where We rely on legitimate interest, We ensure that such interests are balanced against data subjects’ rights and expectations through documented assessments.
6. Data Sharing and Disclosure
6.1. We may share personal data as follows:
(a) With Clipping Platform Operators: for joint controller cooperation and operational coordination based on analysis of their Users.
(b) With Clients: for Campaign reporting, analytics, transparency and their internal business purposes, using aggregated or pseudonymized data where appropriate.
(c) With Users: to display performance outcomes, including the value of payouts earned and the Client or Campaign that awarded them.
(d) With Service Providers: including cloud hosting, analytics, AI-based video analysis, payment processors, and compliance vendors, each bound by confidentiality and data-processing agreements.
(e) With Internet Media Platforms: where required to verify performance metrics or for brand-safety and compliance checks.
(f) With Authorities or Advisors: to comply with applicable law, enforce rights, or respond to lawful requests.
(g) With Affiliates: within Our group for payout facilitation, legitimate business and administrative purposes under Our instructions and equivalent safeguards.
6.2. We do not sell personal data. Clients may use Campaign performance data and related analytics for their own legitimate promotional or business evaluation purposes, as permitted under the CPTs, agreements with Clients and applicable law.
7. INTERNATIONAL DATA TRANSFERS
7.1. We are headquartered in the United States. Personal data may therefore be transferred to and processed in jurisdictions that may not offer the same level of protection as the data subject’s country of residence.
7.2. Where required by applicable law, We implement appropriate safeguards for international transfers, including Standard Contractual Clauses (SCCs) or other legally recognized mechanisms.
8. DATA RETENTION
8.1. We retain personal data for as long as necessary to:
(a) perform Our contractual obligations under the CPT and agreements with Clients;
(b) comply with legal or accounting requirements;
(c) resolve disputes and enforce rights; or
(d) maintain a reasonable archival and audit record.
9. COOKIES AND SIMILAR TECHNOLOGIES
9.1. We use cookies and similar technologies on the Website.
(a) Types of Cookies
(i) Necessary Cookies: Necessary for website functionality, security, and session management. These cannot be disabled.
(ii) Analytics Cookies: Used to understand website traffic and performance.
(iii) Functional Cookies: Used to help perform certain functionalities like sharing the content of the Website on the social media platforms, collecting feedback, and other third-party features.
(iv) Performance Cookies: Used to understand and analyse the key performance indexes of the website which helps in delivering a better user experience for the visitors.
(v) Advertising Cookies: Used to provide visitors with customised advertisements based on the pages you visited previously and to analyse the effectiveness of the ad campaigns.
(b) Cookie Management
The Website uses Cookieyes to manage user consent. Cookie preferences apply across Our Website and any embedded scheduling or sign-in modules using the same domain or sub-domain.
Non-essential cookies are activated only after a user has provided consent through Cookieyes’s preference center. Users can withdraw or modify consent at any time by adjusting their Cookieyes settings.
We and Our analytics and advertising partners may collect information about Your use of the Website over time and across devices through cookies, pixels, and similar tools to measure engagement and improve Campaign targeting. You may control or disable these cookies through Your browser settings or the Cookieyes interface. Opt-outs are browser- and device-specific.
Detailed information on each cookie category, duration and description is available through the Cookieyes interface.
10. SECURITY MEASURES
10.1. We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. These include encryption, access control, network monitoring, least-privilege principles, incident-response procedures, and secure cloud environments.
10.2. No transmission over the Internet can be guaranteed to be completely secure. Users are encouraged to maintain appropriate security measures on their own devices.
11. DATA SUBJECT RIGHTS
11.1. We honor all data subject rights under the data privacy laws, regardless of the individual’s location.
11.2. Data subjects may, subject to applicable law, exercise the following rights:
(a) Access: Obtain confirmation of whether We process their personal data and receive a copy thereof.
(b) Rectification: Request correction of inaccurate or incomplete data.
(c) Erasure (“Right to be Forgotten”): Request deletion of data under applicable conditions.
(d) Restriction: Request limitation of processing where contested or unlawful.
(e) Portability: Receive personal data in a structured, machine-readable format and transmit it to another controller.
(f) Objection: Object to processing based on legitimate interests or direct marketing.
(g) Withdrawal of Consent: Withdraw any consent previously given without affecting the lawfulness of prior processing. Upon withdrawal, certain features or services may no longer be available.
(h) Filing a complaint: Lodge a complaint with a competent data protection authority, in particular, in the region of habitual residence.
11.3. We will respond to verified requests without undue delay and within statutory deadlines.
11.4. Requests can be submitted via Contact Information below. We may require reasonable verification of identity before fulfilling requests.
12. AUTOMATED DECISION-MAKING AND PROFILING
We may use automated systems, including AI-driven video analysis and evaluation tools, to assess User Content performance, verify authenticity, or determine eligibility for Campaign payouts. Such processing:
(a) is necessary for the performance of the CPTs and agreements with Clients;
(b) does not produce legal or similarly significant effects without human review; and
(c) is subject to safeguards allowing Users to request human intervention, express their viewpoint, or contest a decision.
13. CONTACT INFORMATION
13.1. For any privacy-related inquiries, requests, or complaints, please contact:
Momentist Privacy Team
Email: privacy@evangelist.so
Momentist, Inc., 169 Madison Ave #38364, New York, NY 10016, USA
13.2. We have designated a Privacy Team responsible for ongoing compliance and oversight under this Policy.
14. UPDATES TO THIS POLICY
14.1. We may amend this Policy from time to time to reflect changes in its practices or legal requirements.
14.2. Updated versions will be posted at the Website with a revised “Effective Date.” Where required by law, significant changes will be notified through the Website, Clipping Platform Operators, Clipping Platforms or emails.
14.3. Continued use of the Website, Management Platform or participation in Campaigns after such updates constitutes acceptance of the revised Policy.
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