Privacy & cookies notice
Last updated 12 September 2026 · Data controller: Trepte Ventures UG (haftungsbeschränkt), Rügenwalder Straße 24, 22143 Hamburg, Germany · trepteventures@proton.me
1. Who we are
FollowerX is operated by Trepte Ventures UG (haftungsbeschränkt), Rügenwalder Straße 24, 22143 Hamburg, Germany, registered at the Amtsgericht Lübeck under HRB 19648 HL and represented by its managing director Robin Trepte. We are the data controller for personal data described in this notice.
For any privacy question or to exercise your rights, contact trepteventures@proton.me or write to us at the postal address above.
2. What we collect
Account and contact data: name, business email, company name, role, telephone number where you provide it.
Transaction data: purchases, token balance and spend history, invoices, billing address, tax identifiers and the last four digits and type of the payment instrument. We never receive or store full card numbers.
Service data: brand materials you share with us, approvals, briefs, messages exchanged with your team, and performance data exported from your social accounts.
Technical data: IP address, device and browser type, pages viewed and referring URL, collected through essential and (with consent) analytics cookies.
Recruitment data, where you apply for a role: CV, portfolio, right-to-work confirmation and interview notes.
3. Why we use it and our lawful basis
To deliver the services and manage your account — performance of a contract.
To take payment, issue invoices and meet tax and accounting obligations — legal obligation and performance of a contract.
To provide support and respond to enquiries — legitimate interests in running a service business, or contract performance.
To send the newsletter or marketing emails — your consent, withdrawable in one click in every message.
To measure and improve the website — your consent for analytics cookies.
To detect and prevent fraud, and to establish or defend legal claims — legitimate interests.
4. Who we share it with
Payment processing: Stripe, acting as an independent controller for payment data under its own privacy policy.
Infrastructure and tooling: hosting, email, analytics, customer support and project management providers acting as our processors under written data processing agreements.
Social platforms: only through the access you grant us, and only to perform the services.
Professional advisers, auditors and authorities where we are legally required to disclose.
We do not sell personal data, and we do not share it for cross-context behavioural advertising.
5. International transfers
Some providers process data outside the European Economic Area. Where that happens we rely on an adequacy decision or on the European Commission’s Standard Contractual Clauses together with supplementary technical measures. A list of current sub-processors and the safeguards applied is available on request.
6. How long we keep it
Account and service data: for the life of the relationship and six years after the final invoice, to meet statutory accounting and limitation periods.
Platform access and brand materials: deleted within 30 days of the account closing, unless you ask us to keep them.
Marketing contacts: until you unsubscribe, then a suppression record only.
Recruitment data: twelve months after the process ends, unless you ask us to keep it longer.
Website analytics: 14 months.
7. Your rights
Subject to local law you have the right to access your data, to have it corrected or erased, to restrict or object to processing, to data portability, and to withdraw consent at any time without affecting prior processing.
To exercise any of these, email trepteventures@proton.me from the address we hold. We respond within 30 days and will never charge you for a request.
You also have the right to complain to your local supervisory authority. For our establishment this is Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit, Ludwig-Erhard-Straße 22, 20459 Hamburg.
California residents may request disclosure of the categories of personal information collected and request deletion; we do not sell personal information as defined by the CCPA.
8. Security
Access to client data is role-based, logged and reviewed quarterly. Two-factor authentication is mandatory for every employee. Credentials are stored in a managed password manager and never shared in plain text. Data is encrypted in transit and at rest with our infrastructure providers.
If a breach affects your rights and freedoms we will notify you and the relevant supervisory authority without undue delay and within 72 hours of becoming aware of it.
9. Children
Our services are sold to businesses and are not directed at children. We do not knowingly collect personal data from anyone under 16. If you believe we have, contact trepteventures@proton.me and we will delete it.
10. Changes to this notice
We will post any change here and update the date at the top. Where a change materially affects how we use your data, we will notify you by email at least 30 days in advance.
Cookies we set
Analytics and marketing cookies are only set after you give consent through the banner, and you can withdraw consent at any time by clearing the site data in your browser or emailing trepteventures@proton.me. Blocking essential cookies will prevent checkout and account access from working.