Privacy Policy
Draft for review · Effective date not set
This draft explains information handled by the current Lawton Ventures campaign tracker and distinguishes it from planned features. Lawton Ventures LLC (“Lawton Ventures,” “we,” or “us”) operates the tracker for creator marketing campaigns.
Launch blockers to confirm
- Approve retention periods and backup handling, and put the reviewed deletion workflow into operation.
- Confirm the hosting/database region and applicable privacy-rights process with Replit and counsel.
- Before enabling TikTok API access, implement authorization, token revocation, data deletion, and an updated notice.
1. Information handled today
Creator registration and sign-in use an external Clerk application. Creators can verify their email using a one-time code or continue with Google when that option is configured. Creators are not asked to create a Lawton Ventures password. The application verifies Clerk-signed creator sessions on the server. Administrator password sign-in remains separate and creator accounts do not grant administrative access.
The Lawton Ventures database stores a stable creator ID, Clerk identity and instance reference, verified primary email, display name, optional manually entered TikTok username, and profile creation/update timestamps. A TikTok username entered in a profile is not verified ownership. Creators can save multiple social-account handles, join campaigns after accepting versioned rules, and submit video links. We store account review status, optional manually checked follower counts and dates, rules versions and acceptance timestamps, submissions, review decisions, manual view records, reserved payout ceilings, approved earnings, and manually recorded payment history. Creators see only their own individual submissions, performance and earnings; authorized campaign clients and admins can view records for the campaigns they manage.
Optional PayPal email or Venmo payment identifiers are encrypted at rest and masked in creator responses. An authorized admin can explicitly reveal a destination to make a payment outside this app; that access is logged without copying the identifier into the event log. This app does not send payments or store payment-provider passwords. Payment preferences and social-account management do not authorize access to a social platform.
Artwork uploaded by an administrator is re-encoded to remove image metadata and stored in App Storage for public display. Only assets authorized for public use should be uploaded; do not upload private creator documents or sensitive verification evidence as campaign artwork.
The service does not currently connect to a creator’s TikTok account, receive TikTok authorization, or fetch private or official TikTok analytics. TikTok API tracking is planned only; it is not an existing feature. TikTok authorization is not required to create a Lawton Ventures account.
Preview provider evaluation, not approved production tracking: ScrapeCreators is being evaluated separately for public TikTok profile bios, stable account IDs, follower counts, video author IDs, and public video metrics. When an ownership check or video check is requested, the service sends the public username or video link to ScrapeCreators using a server-side key. We store ownership-challenge hashes and expiry/check times, verified account IDs and follower counts, submitted video links, timestamped view observations, review states, and provisional earnings. Full raw bios, downloaded media, and raw provider responses are not retained by this integration. A creator chooses to display a temporary ownership code in their public TikTok bio and may remove it after verification. This is not TikTok Login Kit, OAuth consent, or official TikTok authorization.
ScrapeCreators may retain response data, request metadata and operational logs under its own privacy policy and terms. Our usage ledger records endpoint types, timestamps, credit costs and safe error categories, without raw bios or API credentials. Production provider access and scheduled tracking remain disabled pending permission and privacy review. ScrapeCreators' contract does not establish TikTok's permission to extract data. New tracking-data retention periods, processor arrangements, deletion verification, backup treatment and any legally required financial-record retention require approval before launch.
For campaign management, an admin may enter artist and campaign names, billing type and campaign settings, target post counts, status, TikTok video URLs, usernames parsed from those URLs, optional post labels, manually recorded view counts, delivery status, and timestamped view history.
The admin password is checked against a server-side secret and is not stored in the campaign database. Admin access is limited to 12 hours after sign-in. The browser session cookie is signed, not encrypted, and has a 12-hour lifetime that can be renewed when the session is used. The app keeps source IP addresses and failed sign-in timestamps in an in-memory rate-limit registry. Old attempts are checked on subsequent sign-in attempts, but the registry has no scheduled purge and IP entries can remain until the process restarts. This is not a finalized retention rule.
Clerk separately manages creator authentication cookies, email verification-code delivery, session expiry, and abuse controls. Our creator routes check the signature, issuer, expiry, and authorized origin of the Clerk session, and creator changes require a session-bound anti-forgery token. We do not store Clerk email verification codes or creator passwords in the campaign database. Public-bio ownership challenges are distinct from email sign-in codes; only their hashes are stored. Signing out ends the creator session; it does not delete the local profile or provider account. Clerk's own authentication and security records follow its applicable settings and practices, which must be confirmed before final publication.
Server request logs can contain IP addresses and requested URL paths, including private campaign-link tokens. TikTok thumbnail lookup logs can contain submitted video URLs. Log access, retention, redaction, hosting location, and backup handling must be confirmed before this policy is finalized.
2. Public TikTok information and embeds
When an admin adds a TikTok video URL, the server may send that URL to TikTok’s public oEmbed service to request thumbnail metadata. Legacy report and marketplace view counts are entered manually by an admin; the separate provider preview can store public observations from ScrapeCreators as described above. No official TikTok analytics API is active. A campaign report links to TikTok video pages and may load TikTok-hosted thumbnail images. If you open a TikTok link, TikTok may receive connection and usage information under its own privacy practices.
3. Planned authorized TikTok access
Creator-authorized TikTok account information and analytics are not currently collected because the authorization and API integration have not been implemented. If this feature is introduced, it should be enabled only after the creator authorizes access, and this policy and the product’s revocation, retention, and deletion procedures must be updated before launch. This draft does not promise a currently available in-app authorization or revocation control.
4. How information is used
Campaign information is used to coordinate campaign work, record submitted posts and manual performance updates, calculate campaign report estimates, display campaign dashboards, export campaign CSV reports, maintain admin access controls, and respond to requests or legal obligations. Creator identity and profile information is used to create and secure an account and let the creator view and update their own profile. It is not automatically attached to existing campaigns by matching a username or email.
5. Sharing and service providers
Campaign information is shown to the relevant campaign clients through an unlisted, read-only campaign link. Anyone who receives or is forwarded that link can view its campaign report. Each link is limited to one campaign and can be rotated or revoked by an admin.
Separately, administrators may explicitly publish a creator campaign brief, approved artwork, creator rate and public creator budget for anyone to browse without signing in. Private client reports, client billing and participant details are not automatically included. If public artwork is hosted by another service, that host receives the visitor’s normal connection information when the image loads; artwork requests use a no-referrer policy.
The application is configured to run on Replit using a PostgreSQL database in production. Hosting, database region, subprocessors, backup schedules, and operational-log retention require confirmation from the applicable service configuration and agreements. Clerk processes creator authentication information, including email, sign-in/session activity, and browser/network information needed to operate its service. Google processes Google sign-in when the creator chooses that option; the app uses the verified identity/profile returned through Clerk, not Google contacts, mail, or calendar access. Provider contracts, subprocessors, regions, and retention must be reviewed before final publication.
TikTok receives video URLs for public thumbnail lookups and may receive visitor connections when a person follows a video link or loads TikTok-hosted content. The current application code has no payment processor, advertising pixel, separate site-analytics service, or email marketing provider. This code audit does not establish what separate business tools Lawton Ventures uses outside the application. Campaign payments are not processed by this app.
6. Storage and security
Campaign records are stored in the application database. The app uses admin password authentication, CSRF checks for administrative changes, and separate unlisted campaign tokens. In production mode it configures HTTPS-only session cookies. Client links are bearer links, not individual client authentication: possession of a link permits viewing and CSV export for that campaign. The current app has no individual admin identities or administrator multi-factor authentication. Deletion cases have a restricted decision history and a fulfillment hold/review control, but the shared administrator login does not independently verify the operator alias entered in that history. These controls are not an audit log or legal-hold system for every business tool. We do not claim a security certification, independently verified encryption at rest, or a guarantee that any system is completely secure.
7. Retention and deletion
Creators can request account and personal-information deletion from their account settings, or contact the address below if they cannot sign in. In-app requests require a verified account, a live Clerk session created within the previous five minutes, a session-bound anti-forgery check, and explicit confirmation. If the session is older, sign out and sign in again. Someone unable to sign in requires independent manual ownership verification; a TikTok username or campaign link alone is insufficient. We do not request government identification by default.
A request receives a case reference and pauses local creator-profile access. Requests enter a restricted administrator review queue; submission is not a promise of immediate deletion. An authorized reviewer must confirm the scope, any legally necessary financial, tax or compliance retention, and external-system follow-up before approving fulfillment. A specific retention obligation or unresolved legal review pauses processing and must include a documented basis, necessary record scope and review date. This is not authority to keep all information indefinitely. Retention schedules, jurisdiction-specific response deadlines, appeals, request-evidence retention and backup/log handling still require owner/legal approval before this draft becomes final. No statutory deadline is invented or suspended by this process.
After approval, a retryable background process deletes the Clerk account, confirms its absence, and removes the local creator profile, participation links and creator submissions. Only campaign posts explicitly identified and approved as in scope have personal identifiers, video links, labels and thumbnails removed. Shared campaigns, unrelated posts, other creators’ information, administrator data, report totals and non-identifying numerical history are not automatically deleted. Reports with residual reidentification risk require manual handling before approval. Deletion here does not remove an original TikTok account or video.
The app periodically checks existing local accounts through Clerk’s authenticated API while the service is running. A confirmed provider-side account deletion creates the same restricted review case; it does not automatically erase shared campaign records. Network errors are not treated as proof of deletion. Unverified processing and repeated failures stay visible for administrator intervention rather than being reported complete. Background processing and reconciliation depend on service availability and are not instantaneous.
Completion evidence records the case reference, dates, decision events, operation counts and verification results—not a copy of deleted profile content. Provider identifiers and scope notes are cleared from completed cases. Keyed, pseudonymous suppression fingerprints remain to prevent recreation and support deletion replay before restored backups are served. These fingerprints are still restricted data; their retention period and the minimum case-evidence period require approval. Clerk may separately retain security or other records under its applicable obligations and practices; deleting a provider account does not certify erasure of every provider backup or log.
Database deletion does not itself erase downloaded client reports, forwarded copies, mailbox records, operational logs or backups. The reviewer must resolve or document these separately before approval and explain any lawful retained categories and reasons to the requester. Until approved schedules and operational ownership are in place, affected requests remain under review rather than being automatically closed. Use your case reference when contacting us for progress, corrections, or escalation. Creator self-service data export is not implemented.
Deletion review also covers social handles, ownership-review evidence, rules acceptances, submission URLs and encrypted payment preferences. Linked TikTok preview accounts, ownership challenges, submitted videos and their observation history are deleted with the creator; aggregate provider-credit usage contains no creator identifier. Outstanding accepted-video reservations or unpaid approved earnings require manual financial resolution before automatic fulfillment. Paid numeric campaign/payment totals can remain anonymous; creator links, payment destinations and external receipt references are removed during fulfillment. This does not establish a legal retention schedule or replace a documented, justified hold for any identifiable tax or compliance records. Exact video suppression fingerprints are recorded at approval and checked during normal ingestion as well as backup replay, so approved removed videos cannot simply be re-added.
8. Revocation of TikTok access
No TikTok account authorization is currently collected, so there is no active TikTok authorization for a creator to revoke through this tracker. If authorized TikTok tracking is added, creators should be able to revoke access through TikTok and contact us about associated data. That process must be implemented and its handling rules confirmed before the feature is enabled.
9. Privacy rights and children
Creator campaign participation is limited to adults 18 or older. Where applicable law provides privacy rights, individuals may contact us to request access, correction, deletion, or a copy of their information. The rights available, verification process, response deadlines, and any appeal procedure depend on applicable law and must be confirmed with counsel before publication. We do not knowingly seek personal information from children under 18.
10. Changes and contact
We may update this policy as the tracker changes. Any future TikTok authorization or analytics feature requires an updated privacy notice before collection begins. For privacy questions or requests, contact luke@lawtonventuresllc.com.