Version 1.7 · effective from October 10, 2026 · older versions · Česky
This version is no longer in effect. The current one is version 1.16.
This is an English translation. If it differs from the Czech version, the Czech version prevails.
What this means in practice
We describe what data we have about you, what we use it for and how long we keep it. We never pass your address or phone number to brands; your email only if you share it yourself. We store diet, allergies and skin type only with separate consent, and we delete them when you withdraw it.
Contents
1.1 The controller of personal data is Fomigo Solutions s.r.o. · Company ID (IČO) 300 03 407 · Příčná 1892/4, 110 00 Prague 1 · registered with the Municipal Court in Prague, Section C, File 455688 (“Fomigo” or “we”).
1.2 In matters of personal data protection, contact us by email at contact@fomigo.com or by post at our registered office address. We have not appointed a data protection officer, because the scope of our processing does not yet require one. If that changes, we will name them here.
1.3 This Policy explains what data we process, why, for how long, who we pass it to and what rights you have. It supplements the Fomigo Terms of Service and covers processing in the fomigo.com application.
| Data | Source | Note |
|---|---|---|
| Account: email, name, nickname; sign-in is provided by Google Identity Platform (password or sign-in with Google/Microsoft) | from you at registration | the password is stored not by us but by Identity Platform |
| Social media account (handle) and verification status | from you; verification by connecting the account (OAuth) | Article 9 |
| Profile and statistics of the connected channel (YouTube, Instagram, TikTok): account identifier, name and handle, profile photo and bio, numbers of followers, views, posts and likes; for YouTube and Instagram also the audience breakdown by age, for YouTube also by gender — including data that the network does not show publicly | from the social network's API, to the extent you approve when connecting | Article 9 |
| Delivery address (street, postcode, country) or the Zásilkovna/Packeta pickup point you chose on the map, phone number, date of the last address confirmation | from you | the live address is protected by database encryption and access control, not by application-level encryption — see Article 11 |
| Preferences: “want” and “don't want” categories, clothing and shoe size, children (age bands only), pets | from you | no reason for declining a category is stored, because it could reveal health, religion or other sensitive circumstances |
| Date of birth | from you, optionally in your “About me” profile | Article 14 |
| Diet, allergies (including free text) and skin type | from you, only with separate explicit consent | special category of personal data (Article 9 GDPR) — see Article 5 |
| Shipments: status, delivery history, value of the products as stated by the Client | from the operation of the Platform | |
| Outputs: links to content that you reported or that the Modash import finds, public metrics of the output, stored preview | from you; from the publicly available content of your listed accounts | Articles 4 and 8.4 |
| Reputation group (A–D) and the underlying events (delivered, published, promise kept/not kept) | calculated from the above, once a week | Article 12 |
| Consents and their versions, time given; record of sharing your email with a specific brand | from the operation of the Platform | Article 7 |
| Communication with support, notifications we have sent you | from the operation of the Platform | |
| Technical data: IP address, device and browser type, sign-in records | automatically |
| Data | Source |
|---|---|
| Handle and publicly available social media profile data (content category, audience, contact email given in the public profile), a snapshot of public channel statistics | from a list export from the Modash tool |
| Handle and contact email | from a brand's own contact list given to us (in that case the brand is the source — Article 6.2) |
| Code/Invitation Link: when it was created and which offer it belongs to | from the operation of the Platform |
| A record that you were sent the information under Article 14 GDPR, and a record of any objection to being contacted | from the operation of the Platform — see Article 6 |
| Data | Source |
|---|---|
| Name, work email, phone number, role and the company you represent | from you or from a colleague who invited you |
| Company identification and billing details (name, registered office, company ID (IČO), VAT ID (DIČ), billing email) | from you; supplemented from the public ARES register |
| Briefs, orders, Campaign settings, preview approvals, acceptance of terms (version, time) | from the operation of the Platform |
| Technical data about use of the portal | automatically |
Your name and email were given to us by the Client, or entered by our salesperson according to whom the Client designated. From you, we have your position, your declaration on the Order, the times of the steps, your IP address and browser data. You confirm the Order through the link sent to your email; together with the Order, we keep the accepted text of the Proposal with your name, position and declaration, and when we sent you the link. We send the email with the Proposal Link from noreply@fomigo.com; a copy of it stays in the sent mail of the Fomigo mailbox we send from (Google Workspace, Article 8.2). The Client also receives a confirmation of every Order.
Technical data needed to display the public pages of fomigo.com (IP address, requested page, browser). We choose the language of the pages based on the languages set in your browser, the page you came from and the country that our hosting provider (Google Cloud) determines from your IP address. We store none of this for the purpose of choosing the language. The application uses no cookies other than strictly necessary ones: the session cookie after sign-in, short-lived step cookies during registration, channel connection and when creating an account from a Proposal Link, and the language cookie (Article 13). A visitor who does not start registering or sign in receives at most the language cookie, and only if they choose a language themselves or arrive from a page whose domain determines the language (for example .cz).
| Purpose | Who it concerns | Legal basis |
|---|---|---|
| Running the account, sign-in, security, communication about the account | Creator, Client user | performance of a contract (Article 6(1)(b) GDPR) |
| Selecting Creators for Campaigns based on profile, preferences and reputation group; delivering the Package; SMS and email about the shipment, without confirmation of each Package in advance | Creator | performance of a contract — consent to being sent Packages is part of the terms accepted at registration (Terms of Service, Article 17) |
| Annual address confirmation | Creator | performance of a contract; the principle of data accuracy |
| Date of birth as an additional confirmation that the Creator is at least 18 | Creator who entered the date | legitimate interest — only persons aged 18 and over may use the Platform (Article 6(1)(f) GDPR); the data is optional and you can delete it from your profile at any time |
| Finding Outputs and public metrics on the listed public accounts for 60 days from delivery | Creator | performance of a contract (description of the service) and our legitimate interest in verifying what came of the Campaign — this is not consent: a withdrawable consent would remove, in the middle of the monitoring window, the basis for the reporting that is owed to the Client |
| Processing the delivery address and its encrypted snapshot on the shipment | Creator | performance of a contract — this is not consent: a withdrawal in the middle of transport would remove the basis for an address the carrier already has |
| Calculating the reputation group, matching and the check before the first Package | Creator | performance of a contract and legitimate interest in the quality of the database and in protecting Clients |
| Sharing your email with a named brand (Article 7) | Creator | consent — the consent is the act of ticking the box or clicking the button in the request itself; it can be withdrawn until the sharing takes place |
| Consent to the health fields (diet, allergies, skin type) | Creator | explicit consent (Article 9(2)(a) GDPR) — see Article 5 |
| Identifying and approaching a Creator who is not yet with us, with a specific Package offer; recording an objection so that we do not approach them again | Creator before registration | legitimate interest — see Article 6 |
| Approaching contacts from a brand's own list | Creator before registration | legitimate interest; the source of the data is the brand, which is their controller and is responsible for informing them |
| Handling Client registration, preparing the Proposal, concluding and performing the Order, invoicing | Client user | performance of a contract or negotiations on it, where the Client is a self-employed natural person; for employees and representatives of the Client, legitimate interest (Article 6(1)(f) GDPR); compliance with legal obligations (accounting, tax) |
| Concluding an Order via a Proposal Link and keeping evidence of it | person confirming an Order on behalf of the Client | legitimate interest — concluding the contract with the Client and being able to prove and defend it (Article 6(1)(f) GDPR); you can object to the processing under Article 21 GDPR (see Article 16) |
| Operational and legal notices (selection for a Campaign, offers and shipments, account verification, change of terms); we do not send Creators news or commercial communications | all users | performance of a contract; cannot be switched off |
| News about Fomigo by email | Client user who asked for it at registration | consent (Article 6(1)(a) GDPR; Section 7 of Act No. 480/2004 Coll.) — optional, until withdrawn; you can unsubscribe via the link in every email or at contact@fomigo.com |
| Handling data subject requests, defending legal claims | everyone | compliance with legal obligations; legitimate interest |
We do not automatically process any special categories of personal data other than the fields under Article 5 (diet, allergies, skin type). Preferences for declined categories do not contain a reason.
5.1 The optional fields for diet, allergies (including free text) and skin type in the “About me” profile may reveal a health condition and are a special category of personal data under Article 9 GDPR. They are shown and saved only with your explicit and optional consent, given with a box that is not pre-ticked, separate from your consent to the Terms, with a link to this Policy (Article 9(2)(a) GDPR). Without consent, the fields are inactive and nothing is saved. You still receive offers.
5.2 The data is used solely so that we select and pack Packages that cannot harm you. The Client never sees it. Our internal team sees it only when packing a shipment.
5.3 You can withdraw consent at any time in settings, as easily as you gave it. Withdrawal deletes the diet, allergies (including free text) and skin type fields. Nothing already under way ends because of it; only the basis for future selection and packing changes.
5.4 Children in the household are recorded only as age bands, never by name or date of birth. We never collect information on glasses, eyeglass prescriptions, skin tone or hair type.
6.1 Modash import. If we identified your channel from publicly available data using the Modash tool, we process the categories of data under Article 3.2 on the basis of legitimate interest: offering a Package to the people concerned.
6.2 A brand's list. If we received your contact details from a Client who knows you (its own list under the Terms of Service, Article 10.2), the source of the data is that brand. As controller, the brand is responsible for obtaining the data lawfully and for informing you in advance.
6.3 When and how we inform you. You receive the information under Article 14 GDPR — where we got the data, what categories we process and how to object — no later than with the first invitation email, and nothing else is sent to you before it.
6.4 Right to object. Every invitation email contains the link “I don't want you to contact me”. This is an objection under Article 21 GDPR to processing based on legitimate interest. Once you click it, no invitation or message is sent to you from that moment on, and we do not select you for Campaigns. At your request, we delete the data. We keep only a one-way fingerprint (hash) of the email and the channel identifiers, from which the original value cannot be read. It serves only to prevent a further Modash import from inviting you again.
6.5 Person confirming an Order. We have the name and email of the person to whom we send a Proposal Link from the Client; they receive the information about the processing in the email with the link.
7.1 After the Campaign ends and the report is sent, the Client may ask once per Campaign for the contacts of the selected Creators. You give consent either with an optional checkbox that is not pre-ticked, on the selection notification or on the feedback for that Campaign, or with a button in a specific brand's request. The text is always the same: “I agree to share my contact with {Brand}”.
7.2 The legal basis is your consent (Article 6(1)(a) GDPR), always for a specific named brand and a specific Campaign — never a general consent “to brands” and never a profile preference.
7.3 What is shared: name, channel handle and contact email. Your address and phone number never leave the Platform, under any circumstances.
7.4 The consent is used up by a single sharing. What has been shared cannot be taken back. Because the consent is one-time and nothing continues to run from it after the sharing, there is nothing to “withdraw” as a standing setting. Every further request, even from the same brand for another Campaign, asks you again.
7.5 After the sharing, the brand becomes an independent controller of your contact, not our processor, and is responsible for its further processing. The business (B2B) terms oblige the brand to use the contact only to approach you about follow-up collaboration.
7.6 Declining or silence has no consequences for you. Our internal team sees each Creator's answer; the Client sees only the number of Creators who agreed, and the contacts of those who agreed. It will not find out who declined or did not respond.
The Client that sends you a Package does not receive your address or phone number — ever. It receives your email only if you have given it yourself under Article 7. At that point, the Client is the independent controller of your email and is responsible for its further processing.
The Client does not receive data from your connected channel (Article 9) individually. In the Proposal, it sees only aggregate figures for the Creators selected for the Campaign: how many there are on each network and in each size group, what share have a verified channel, the median number of followers, the countries Packages are sent to, and the share of Creators in reputation groups A and B. By name, it sees only the handles of Creators whom it has itself given us as its existing collaborators. In the Campaign report, it sees the Creator's handle and links to their Outputs with public metrics. These come from publicly available content (Article 8.4) and from links the Creator reported, not from the connected channel.
To run the Platform, we use suppliers who process data on our instructions and on the basis of a data processing agreement (Article 28 GDPR):
Modash is a third-party tool that we use in two ways: as a data source when identifying new Creators (list export, Article 6.1), and as a tool whose regular Campaign monitoring export evaluates the publicly available content of Creators' accounts for the purposes of the report. Modash processes only publicly available social media data. For Output monitoring, Modash is our processor and processes data on our instructions on the basis of a data processing agreement (Article 28 GDPR). For identifying new Creators, it is a provider of publicly available data from which we make the selection (Article 6.1).
You connect a YouTube, Instagram or TikTok channel yourself in the Portal, through that network's sign-in (OAuth). The connection is read-only: we will never publish, change or delete anything on your account. We use the retrieved data to verify that the channel belongs to you, to show you and our team its size and audience, to select Creators for Campaigns and to compile aggregate figures for Clients (Article 8.1). We do not sell data from connected accounts, do not use it for advertising and do not pass it to anyone other than the processors under Article 8.2. We store it in the database with the connected channel (Article 11.1), together with the original response from the network's API, from which we remove access tokens and email addresses. The access tokens themselves are also encrypted (Article 11.3).
Connecting a YouTube channel uses YouTube API Services. By using this feature, you agree to the YouTube Terms of Service and acknowledge the Google Privacy Policy, under which Google handles your data.
We request only two permissions:
Fomigo's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
We check the validity of the authorisation for a connected YouTube channel at least once every 30 days. If we find that you have revoked access yourself at Google, we proceed as with a disconnection (Article 9.5).
You can connect an Instagram professional account (Creator or Business). We request the instagram_business_basic permission — account identifier, username, name, account type, profile photo, bio and profile website, number of followers and posts — and the instagram_business_manage_insights permission — the age breakdown of followers (Instagram provides it only for accounts with at least 100 followers). We do not publish, comment or send messages. On the consent screen, Instagram shows us under the name “Fomigo-IG”.
We request the user.info.basic, user.info.profile and user.info.stats permissions: account identifier, display name and username, profile photo, bio, profile link, whether the account is verified, and the numbers of followers, likes and videos. We do not read the list of your videos, and we do not share anything to TikTok.
After the channel is disconnected in any of these ways, or after you request deletion of your data, we delete the access tokens and the data retrieved from the channel within 7 days. Only the channel's identification remains — the handle and the account identifier on the network — so that the Campaign history stays with the correct channel and so that we recognise the channel if you connect it again. It is deleted when the account is closed (Article 10).
| Data | Period | Reason |
|---|---|---|
| Creator account and profile | for as long as the account exists; after it is closed, we anonymise within 30 days | enough time to complete shipments under way and handle support, and not much more |
| Date of birth | until you delete it from your profile, at the latest until the account is closed — then we delete it within 30 days | it serves only to confirm age and has no purpose without the account |
| Delivery address and phone number (the live value in the profile) | deleted with the account, within 30 days of its closure | they are the most sensitive data in the profile and have no reason to outlive the account |
| Encrypted address snapshot on an individual shipment | 12 months from delivery, then deleted | covers complaints and returns (Terms of Service, Article 11); it serves no purpose for longer |
| Data retrieved from a connected channel (YouTube, Instagram, TikTok) | until disconnection or a deletion request — then 7 days (Article 9.5) | |
| Validity of the authorisation for a connected YouTube channel | checked at least once every 30 days (Article 9.2) | |
| Data about a Creator before registration (identification, approach, code) | 12 months from the last contact if they do not register; on objection or on request (Article 6.4), deleted immediately, and only the fingerprint under the row below remains | without a time limit, the Modash import would keep unregistered contacts forever |
| Record of an objection to being contacted | after the data is deleted, only a one-way fingerprint (hash) of the email and channel identifiers remains, with no readable value, for as long as we identify Creators by import (Article 6.4) | without the fingerprint, the next import would invite you again |
| Records of consents and their versions | for as long as the account exists + 3 years; for a person without an account, the record follows the row on evidence of an Order | the limitation period for asserting claims — we must be able to prove what was agreed to and when |
| Health fields (diet, allergies, skin type) | until consent is withdrawn — then deleted immediately (Article 5.3) | |
| One-time consent to share a contact, and its record | the consent is used up by a single sharing (Article 7.4); we keep the record of the sharing for 3 years from the sharing | the same limitation period as for other consents — it is proof that the contact was shared, and with whom |
| Reputation group and the underlying events | for as long as the account exists, recalculated once a week; deleted with the account | it is calculated only from the data of an account that has ceased to exist, and has no meaning without it |
| Client data and contractual documentation | for the duration of the contract; accounting and tax documents for 10 years from the end of the year in which the document was created | the period under the Accounting Act and the Tax Procedure Code |
| Evidence of the conclusion of an Order (accepted text, fingerprints, name, position, declaration, the email address the Proposal Link was sent to) | 10 years from the end of the year in which the Order was made | defence of claims within the objective limitation period, and accounting archiving |
| Technical data about the steps of an Order (IP address, browser, copies of the link emails in the sending mailbox) | 4 years from the end of the Campaign; during a dispute, until it ends | the limitation period and a reserve for claims raised at its end |
| Technical records (access logs) | 30 days | enough to trace an incident; not operational analytics |
In this version of the Platform, reading of a Creator's delivery address by an internal user is not audited. Access to the address is controlled by roles (Article 11.4), so the table has no separately logged record of each read.
11.1 The database runs on Google Cloud SQL in the europe-west3 region, with encryption of data at rest and controlled access at the infrastructure level. The live delivery address and phone number in the Creator's profile are protected in this way — by database encryption and access rules, not by application-level encryption.
11.2 In addition, an encrypted address snapshot is created at the moment the Package is accepted and is stored, encrypted at the application level, on the shipment concerned. This is so that it survives unchanged even a later key rotation or a change in the access rules for the live profile.
11.3 The access authorisations (tokens) for connected channels are encrypted, with a key version for future rotation.
11.4 Internal users' access is controlled by roles. Sign-in is provided by Google Identity Platform. Communication is encrypted (HTTPS).
11.5 Suppliers process data on the basis of a data processing agreement and only for the purpose concerned (Article 8.2).
12.1 To select Creators for Campaigns, we use automated evaluation of profiles (categories, preferences, channel verification, reputation group, address availability). The reputation group A–D is calculated once a week from how often you published after a Package was delivered and whether you kept what you promised, compared with comparable Creators on the same network. You see your group in your profile, together with one sentence about what raises it — never the formula, the percentile or other people's figures.
12.2 The Client never sees your group and cannot filter by it. A decision that would have legal effects for you or similarly significantly affect you is not made automatically without the possibility of human intervention: you can contact our support at contact@fomigo.com about your classification or a selection and ask for a human review.
12.3 Creators are selected for Campaigns by our team; automatic filters only make the selection easier for the team. It is therefore not a decision based solely on automated processing under Article 22 GDPR.
13.1 The application on fomigo.com uses only strictly necessary cookies. The main one is the session cookie, which is set when you sign in (httpOnly, valid for at most 14 days). Without it, the Platform would not know that you are signed in, and you could not move between screens of the Portal.
13.2 Alongside it, we use short-lived step cookies, which hold an unfinished step until you complete it:
Step cookies expire once the step is completed or their validity ends.
13.3 Language cookie. When you choose a language in the switcher, or when you arrive at fomigo.com from a page whose domain determines the language (for example .cz), the application stores a cookie with your language choice (only the language code, for example “cs” or “en”, valid for 1 year), so that further pages are shown to you in the same language. It contains nothing else and is not passed to anyone.
13.4 All these cookies are strictly necessary for the service you have requested (sign-in, registration, secure completion of OAuth, display in the language you chose). Under Section 89(3) of Act No. 127/2005 Coll., on Electronic Communications, we do not require consent for them. The Platform uses no other cookie, whether analytical or marketing.
13.5 Because these are only strictly necessary cookies, you will find no cookie banner or cookie settings on fomigo.com. There is nothing to consent to.
14.1 The Platform is intended only for persons over 18. A Creator confirms their age in the first step of registration, together with their agreement to the Terms of Service (Terms of Service, Article 15.1), and may optionally enter their date of birth in their “About me” profile; a date of birth according to which they are not yet 18 cannot be saved. We do not knowingly process the data of persons under 18. If we find that an account belongs to a person under 18, we will close it and delete their data.
14.2 We do not send alcoholic beverages, tobacco or nicotine products through the Platform (Terms of Service, Article 8.4).
14.3 Data on children in a Creator's household are recorded only as age bands, never by name or date of birth (Article 5.4).
15.1 We run the database and the main processing in the European Union (Google Cloud, europe-west3 region). Within Google's global infrastructure (Cloud, Workspace, Identity Platform), limited processing may take place outside the EEA. Such transfers are covered by standard contractual clauses, which form part of the Google Cloud and Google Workspace data processing terms.
15.2 Carriers and other independent controllers under Article 8.3 process data within the European Union. We deliver Packages only in Czechia and Slovakia (Terms of Service, Article 11.3).
16.1 You have the right of access to your data and to a copy of it, the right to rectification, to erasure, to restriction of processing, to portability of the data you have provided to us, and the right to object to processing based on legitimate interest.
16.2 You can withdraw consent (health fields, sharing your contact with a brand, news by email) at any time. Withdrawal does not affect processing before the withdrawal. For a shared contact, withdrawal stops further sharing in the future, but a contact already shared cannot be taken back from the brand (Article 7.4).
16.3 We handle requests sent to contact@fomigo.com within one month. In complex cases, we extend this period by at most two further months and let you know. In this version of the Platform, closing a Creator account (Terms of Service, Article 25), providing a copy of your data and deletion are handled by our support at contact@fomigo.com.
16.4 You have the right to lodge a complaint with the supervisory authority: the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 727/27, 170 00 Prague 7, www.uoou.gov.cz, email posta@uoou.gov.cz.
17.1 We may change this Policy when the service or the law changes. You will always find the current version and its effective date on this page and in the document overview. We inform you of material changes by email or in the Portal.
Fomigo Solutions s.r.o. · Company ID (IČO) 300 03 407 · Příčná 1892/4, 110 00 Prague 1 · registered with the Municipal Court in Prague, Section C, File 455688 · contact@fomigo.com.