Privacy Policy

1. Who We Are

CloutBank is a fintech platform that provides AI-powered credit scoring services specifically designed for content creators and social media influencers. We help creators turn their social influence into financial opportunities through our proprietary Creator Credit Score (CCS) system.

Business Model: We operate as a B2B technology provider to banks and financial institutions, offering white-label creator credit scoring technology while also providing direct services to creators.

2. Data We Collect and Why

YouTube Data Collection (OAuth Integration)

When you connect your YouTube channel to CloutBank, we collect and analyze the following data for credit scoring purposes:

• Channel Analytics: Subscriber count, view counts, engagement rates, and growth trends to assess audience reach and influence
• Content Performance: Video performance metrics, content consistency, and publishing frequency to evaluate content quality and reliability
• Audience Demographics: Age groups, geographic distribution, and audience retention to assess market value and targeting capability
• Revenue Data: YouTube Partner Program earnings, channel memberships, and monetization metrics for income verification
• Engagement Quality: Comment sentiment, like/dislike ratios, and community interaction to evaluate audience quality

Other Platform Data

We similarly collect and analyze data from connected social media platforms including:

• Instagram: Posts, Stories, Reels performance, follower demographics
• TikTok: Video performance, trending participation, audience engagement
• Twitter: Tweet engagement, follower quality, influence metrics
• Twitch: Streaming analytics, subscriber data, donation patterns

Financial and Credit Data

• Bank account information (for income verification)
• Revenue streams and payment history
• Credit history and payment behavior
• Loan applications and approval status

Personal Information

• Name, email address, and contact information
• Date of birth and government ID (for KYC compliance)
• Business information and tax identification
• Banking details for payment processing

3. How We Use Your Data

Creator Credit Score (CCS) Calculation

Your data is processed through our proprietary AI algorithm to generate a FICO-style credit score (300-900 range) specifically for creators. This includes:

• Analyzing 1,504+ data points across all connected platforms
• Assessing audience quality, content performance, and revenue stability
• Predicting creditworthiness and loan default risk
• Generating personalized financial recommendations

Financial Services

• Loan origination and approval decisions
• Risk assessment for banking partners
• Payment processing and transaction monitoring
• Fraud prevention and security monitoring

Platform Improvement

• Improving our AI algorithms and scoring accuracy
• Developing new features and services
• Conducting research on creator economy trends
• Providing anonymized insights to banking partners

4. Data Sharing and Third Parties

Banking Partners

We share anonymized credit scores and risk assessments with our banking partners to facilitate loan approvals and financial services. Personal identifiers are only shared with explicit consent for specific loan applications.

Service Providers

We work with trusted third-party services including:

• Cloud infrastructure providers (AWS, Google Cloud)
• Analytics and monitoring services
• Payment processors and KYC verification services
• Email and communication platforms

Legal Requirements

We may disclose your information when required by law, court order, or to protect our rights and the safety of our users.

5. Data Security and Protection

CloutBank implements enterprise-grade security measures:

• Encryption: All data is encrypted at rest and in transit using industry-standard protocols
• Access Controls: Role-based access with multi-factor authentication
• Compliance: SOC 2 Type II certified with GDPR and CCPA compliance
• Monitoring: 24/7 security monitoring and threat detection
• Regular Audits: Third-party security assessments and penetration testing

6. Your Rights and Control

Data Access Rights

• View all data we have collected about you
• Download your complete data profile
• Understand how your CCS score is calculated

Data Control Rights

• Disconnect any connected social media accounts
• Delete specific data points or entire account
• Opt-out of data sharing with banking partners
• Request data corrections or updates

Communication Preferences

• Control marketing and promotional communications
• Set preferences for credit score update notifications
• Manage loan offer and partnership communications

7. International Data Transfers

CloutBank operates globally and may transfer your data internationally. We ensure all transfers comply with applicable data protection laws and use appropriate safeguards such as Standard Contractual Clauses (SCCs) and adequacy decisions.

8. Children's Privacy

CloutBank services are not intended for users under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected such information, we will take steps to delete it promptly.

9. Changes to This Policy

We may update this privacy policy to reflect changes in our practices or applicable laws. We will notify users of material changes via email and by posting the updated policy on our website with a new effective date.