In this Article:
Last updated: June 22, 2026
1. Introduction
At Later we are committed to the legal processing, confidentiality, and security of all personal information that we handle in connection with the provision of our social media and marketing technology and services, in accordance with all applicable laws and as described in this Privacy Notice (“Notice”).
This Notice describes the personal information that we collect, how that information is processed, and your rights and choices in relation to it.
This Notice applies where we are the entity that decides on the purposes of processing of personal information and the ways in which it is processed within our products and services, also referred to as the “data controller” or “business”. In some circumstances we may process personal information on behalf of our customers and on their instructions (e.g., where we measure and analyze end users’ interactions with their posts and campaigns). There, we act only as a “data processor”, “service provider”, or “contractor”, and, while we will assist as far as we reasonably can, you should submit any questions and requests to the customer in question, as the relevant data controller or business.
Later may change this Notice from time to time, due to changes in our business, technology, applicable laws, or any other reason. Please check this page from time to time to be informed of the latest changes.
2. Who We Are
The “data controller” or “business” in relation to the processing of the personal information as described in this Notice is: Mavrck LLC d.b.a. Later.
Later’s social media and marketing technology and services are provided by Mavrck LLC d.b.a. Later (operating Later Influence and Later Social Enterprise), and/or through our group companies such as MyFavoriteThings, Inc. d.b.a. Mavely (affiliate marketing services for influencers), and Victory Square Media, Inc. (Later Social and Link in Bio). In this Notice, any and all of these Later group entities are collectively referred to as “we” or “Later”.
For any question or request relating to processing of personal information, we can be contacted as set out in Section 9.
3. Categories of Data, Sources of Data, Purposes of the Processing, and Legal Bases for the Processing
Later is a provider of social media and influencer marketing technology and services. Most personal information we process relates to individuals acting in the context of their trade or profession, e.g., creators and influencers on social media (“Creators”) active in a professional capacity, and staff of our brand and agency customers. Some users of our services may be consumers, e.g., non-professional Creators who use Mavely services to earn commissions.
Our principal services currently comprise the following:
- Managed Campaign Services – we manage Creator marketing campaigns for brand customers, including strategy, Creator sourcing, content production, and performance reporting.
- The Later Platform – we provide a self-serve Creator marketing platform that enables our customers to independently manage campaigns, communicate with Creators, and access the Later Influencer Index (Creator database).
- Later Creator Program – we manage this program to enable individual Creators to join our Creator network to be discovered and matched with brand campaigns.
- Later Social – we provide a SaaS social media management tool for social media managers, agencies, and brands that enables scheduling, publishing, analytics, and content management across major social platforms, including our linkin.bio tools.
- Later for Creator (formerly Mavely)– we provide an affiliate marketing platform that allows brands to run performance-based affiliate campaigns, and Creators to generate shoppable SmartLinks for products from participating brands and earn commissions on resulting sales.
In order to provide our services and manage our business, we collect and/or process personal information relating to: (1) Creators; (2) our customers and potential customers; (3) visitors to our websites and social media channels, and users of our mobile applications; and (4) our other business partners. Our services and tools enable our customers to review our Creator databases, but Later does not sell personal information and is not a data broker.
In accordance with applicable laws, we may freely process and share anonymized, aggregated, or de-identified information that does not identify you or your household.
3.1. Creators
| Individuals | Categories | Source | Purpose of processing | Legal Basis | Comments |
| Creators engaged for our customers’ managed campaigns (and where applicable Creator team members with access to accounts) |
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This is obtained directly from you, from social media platforms, or from analytics tools |
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That it is necessary for our legitimate business interests
To comply with Later’s legal obligations
Sensitive personal information such as ethnicity is processed only with your explicit consent
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This information is necessary for the provision of our services, and in any event relates to your business life and business data and so has minimal privacy impact
Payments are processed by our third party payment service providers and although we process information regarding payment amounts, dates and status, we do not normally collect or store your financial account details |
| Creators who sign up for our services (Later or Mavely) (and where applicable Creator team members with access to accounts) |
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This is obtained directly from you |
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That it is necessary for the performance of our contract with you
That it is necessary for our legitimate business interests
To comply with Later’s legal obligations
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This information is necessary for the provision of our services
Payments are processed by our third party payment service providers and although we process information regarding payment amounts, dates and status, we do not normally collect or store your financial account details |
| Other Creators |
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This is obtained from social media platforms or third party data providers |
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That it is necessary for our legitimate business interests
To comply with Later’s legal obligations
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This information is necessary for the provision of our services, and in any event is publicly available data and so has minimal privacy impact |
3.2. Customers and Potential Customers
| Individuals | Categories | Source | Purpose of processing | Legal Basis | Comments |
| Staff of our customers / potential customers (brands/agencies) |
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This is obtained directly from you or from your employer, or in the case of potential customers from public sources, sales events, trade shows, or professional networking |
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That it is necessary for our legitimate business interests
To comply with Later’s legal obligations
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This information is necessary for the provision of our services, and in any event relates to your business life and business data and so has minimal privacy impact |
3.3. Visitors to or websites and social media channels / App users
| Individuals | Categories | Source | Purpose of processing | Legal Basis | Comments |
| Visitors to our websites and social media channels; users of our mobile apps (also applicable to Creators with an account as set out above) |
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Automatically from your browser or device
From contact forms, or inquiries to our public contact addresses |
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Consent where required. Or that it is necessary for our legitimate interests in operating and promoting our website, apps, and business
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This data processing is typical for almost all websites and apps, and does not allow us to identify or contact you (except where you voluntarily provide details or request a contact). You are able to change your cookie consents at any time as set out in our Cookie Notice below |
| Subscribers to email offers or news updates |
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From subscribers directly | To provide information and support, and to promote our products and services | Consent where required. For our legitimate interests in managing and promoting our products and services | You may change your preferences and decline further emails as explained below and in each communication |
3.4. Other Business Partners
| Individuals | Categories | Source | Purpose of processing | Legal Basis | Comments |
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Commercial Contacts Data
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Later will process data about the representatives of business partners or suppliers (or potential partner or suppliers) also including media and PR contacts, e.g.:
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This is obtained directly from you or from your employer, or in some cases from public sources such as trade shows or professional networking |
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For the performance of our contracts with our individual partners and suppliers
That it is necessary for our legitimate business interests
To comply with Later’s legal obligations
|
This information relates to your business life and business data and so has minimal privacy impact |
4. Recipients and International Transfers of Personal Information
We may disclose personal information to the following categories of third parties:
- Our group companies involved with the provision of our products and services;
- Our customers as part of our services;
- Social media platforms, in order to provide integrations and features you request;
- In the event of merger, reorganization, reincorporation, recapitalization, acquisition, or any form of sale of some or all of our assets, personal information held by us may be shared with the buyer.
- Other organizations that provide services in support of our services and business such as:
- providers of IT-related services (e.g., cloud hosting and storage, database management, search engine, CRM services, business tools, ID and authentication, IT infrastructure and management, trouble ticketing, customer support and communications);
- data analytics and reporting providers;
- security, fraud prevention, and risk auditing services;
- website development, hosting, management, and maintenance providers;
- AI and machine learning providers (but we do not use AI to take decisions with legal or other significant impacts and never allow third party AI systems to use personal information for training models or algorithms – please see separate Section below);
- advertising, marketing, and communications service providers (e.g., email and lead management, customer satisfaction surveys); or
- tax processing, accounting, legal, insurance, or payment service providers;
These organizations process personal information and other data on Later’s behalf, but our contracts with them oblige them to meet data protection standards as strict as those that apply to us, and not to use your personal information for any other purpose.
We store personal information in the USA. Your personal information may also be processed on our behalf in any country where we operate or have engaged data processors, e.g., for data hosting or analysis.
Where such disclosures result in a transfer of personal information to places outside the EU/EEA, the UK, Switzerland, or other countries that are officially regarded by EU or UK authorities as having adequate data protection laws, then this will be done only on the basis of legal safeguards aimed at ensuring that your data is kept as secure as under applicable laws. These may include the standard contractual clauses for data exports as issued by the European Commission or another supervisory authority. A copy of such safeguards may be available from us if we receive a valid request.
If Later receives a request for personal information from a government, national security, or law enforcement agency, or other regulator, we would normally comply with such request without notifying affected individuals.
5. AI and Machine Learning
We may use your content, engagement data, and platform interactions to train and improve our AI models, including for content analysis, trend prediction, and service enhancement. This includes analyzing text, images, and video content you upload or link to our platforms. We use artificial intelligence and machine learning technologies (“AI”) to:
- Analyze content performance and recommend optimal posting strategies;
- Match influencers with relevant brand campaigns based on audience demographics and engagement patterns;
- Detect fraudulent activity and fake engagement metrics;
- Personalize platform experiences and suggest relevant features;
- Suggest captions for your scheduled posts;
- Recommend trending topics; or
- Optimize campaign performance.
Automated Decision-Making: Some of our AI systems may make automated decisions, such as campaign eligibility, or content recommendations, however, such decisions do not produce legal or other significant effects, as defined by applicable laws.
6. Storage Period
We only retain personal information for as long as necessary for the purpose for which it was collected.
We may retain data for at least the time that you or your organization has an account, agreement, or other relationship with us. If you have subscribed for an account with us, or to receive a newsletter or other information, we will keep your details until you unsubscribe.
If you unsubscribe or ask for your personal information to be deleted, then we may retain some data with a view to preventing it from being collected or processed again. If we have excluded you from any of our services for any reason (e.g., breach of our terms of service), then we may also retain data in order to prevent repeated signups. We will also keep records of requests that we receive for exercise of individual rights under applicable privacy laws for the legally required period or in line with our recordkeeping policies.
We keep data relating to Creator, customer, or supplier contracts for at least the applicable limitation period for bringing legal claims, in order to be in a position to resolve any such claims. We may also keep data for longer periods where required for accounting, tax or legal reasons (in which case data use will be limited to such purposes).
We may retain and use anonymized, aggregated, or de-identified data indefinitely for analytics, research, and business purposes, including creation, development, and improvement of our products, algorithms, and models, provided that such data does not identify any individual or customer.
7. Your Rights
Depending on your location and the privacy laws that apply to you, you may have all or some of the following rights under those laws:
- To access your personal information;
- To have your personal information corrected or updated;
- To object to processing of your personal information for direct marketing or for certain other purposes;
- To restrict our processing of your personal information in certain circumstances;
- To receive notice of what categories of personal information will be collected and the purposes for which it will be used;
- To receive confirmation of whether or not your personal is being processed, plus information on how it is used, sold or shared;
- To receive a copy in a portable format for transmission to another organization;
- To opt out of sales or sharing, and in some states to opt out of data processing for targeted advertising and/or profiling for significant purposes;
- To request deletion of your personal information (“the right to be forgotten”) (subject to some exceptions e.g. where required for detecting security incidents, exercising free speech, protecting or defending against legal claims, or for internal uses reasonably aligned with consumers’ expectations);
- To limit use of sensitive information to necessary uses;
- To request human review and receive explanations of certain specific automated decisions; and
- Not to be discriminated against based upon your exercise of any of your legal rights relating to your personal information.
If our data processing is based on your consent, then you can always withdraw that consent (but any processing that took place before withdrawal will still be legal).
As a subscriber or customer of one or more of our products and services, a Creator whose details we have obtained from public sources or third party data providers, or in general a potential customer who we believe may be interested in our products and services, we may send you marketing communications in respect of any Later product and service. We will do this only in accordance with applicable laws, any consents that may be required, and this Notice. You can decline such communications at any time by contacting us as set out in Section 9 below or as explained in each communication.
If your information is visible through our services because it is legally and publicly available (e.g., on social media platforms), then such information is normally excluded from the scope of most US state privacy laws and these rights may not apply to you in relation to such data. Please contact us as set out below in case of any doubt.
If you wish to exercise any of the above legal rights, you (or your authorized agent) can write to us using the contact details in Section 9 below, and we will respond within 45 days or as required by applicable laws. If you make such a request, including through an authorized agent, we reserve the right to verify your identity and the agent’s authorization. However, we may not be able to respond to your request if it is not permitted or foreseen under applicable laws. If you believe that we or any customer have not respected your rights, then you also have a right to make a complaint to the data protection supervisory authority in your country.
If we refuse a request to exercise your rights, then you are entitled to an internal appeal. You can exercise this right by contacting us, indicating the decision you wish to appeal and the reasons for the appeal. The decision will then be reviewed by one or more of our executives or legal counsel (who were not involved in making the original decision) and we will inform you of the result of the review.
Our products and services are not intended for children. We do not knowingly collect personal information from or about children. If you believe that we might have any information from or about a child, please contact us as indicated below.
8. Additional Information for California Residents
To supplement the details provided in Sections 3 and 4 of this Notice, we inform you that, during the 12 months before the publication of this Notice, Later collected:
- the following categories of personal information:
- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, or other similar identifiers;
- Personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information;
- Characteristics of protected classifications under California or federal law;
- Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement;
- Geolocation data;
- Audio, electronic, visual, thermal, olfactory, or similar information;
- Professional or employment-related information; and
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
These categories of information were disclosed to our providers of IT-related services (e.g., data storage, websites development, hosting, management, maintenance, or analytics services), and/or marketing, advertising, and communications services, for our business purposes, as referred to in Section 3.
- the following categories of sensitive personal information:
- A consumer’s social security number (used where we need to make payments to you);
- A consumer’s account log-in in combination with any required security or access code, password, or credentials allowing access to an account;
- A consumer’s racial or ethnic origin, religious or philosophical beliefs (where you have voluntarily provided this);
- The contents of a consumer’s mail, email, and text messages (where you correspond with a brand or agency through our services); and
- Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation (where you have voluntarily provided this).
These categories of information were disclosed to our providers of IT-related services (e.g., data storage, websites development, hosting, management, maintenance, or analytics services) for our business purposes, as referred to in Section 3.
The business purposes referred to in this Section include:
- Auditing related to counting ad impressions to unique visitors, and auditing compliance with this specification and other standards;
- Helping to ensure security and integrity;
- Debugging to identify and repair errors that impair existing intended functionality;
- Short-term, transient use as part of your current interaction with us;
- Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services;
- Providing advertising and marketing services;
- Undertaking internal research for technological development and demonstration; or
- Undertaking activities to verify or maintain the quality or safety of, and to improve, upgrade, or enhance our services or devices.
During the 12 months before the publication of this Notice, no personal information was sold.
During the 12 months before the publication of this Notice, Later shared the following categories of personal information:
- Internet or other electronic network activity information (information regarding website visitors and potential customers, used for marketing and business development purposes).
9. Contacting Us
If you wish to exercise any of your legal rights or have any other inquiry in relation to this Notice, please contact us at the addresses below:
Mavrck LLC d.b.a. Later
60 State Street
8th Floor – Suite 810
Boston, MA 02109
United States
Website: later.com
Email: privacy@later.com
Our representatives in Europe are:
EDPO, Avenue Huart Hamoir 71, 1030 Brussels, Belgium
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