Privacy Notice
This Privacy Notice outlines how information about you, which directly identifies you or could potentially identify you (“personal information”), is collected, used, and shared by FeatureFold (“FeatureFold,” “we,” “our,” or “us”). This applies to our Featurefold platform (the “Platform”), our website www.featurefold.com (the “Site”), and other online tools and services linked to this Privacy Notice (collectively, the “Service”).
GLOBAL APPLICABILITY AND REGION-SPECIFIC DISCLOSURES
This Privacy Notice applies to visitors of our Site and users of our Services. In certain jurisdictions, we may provide additional disclosures to comply with regional laws regarding the handling of personal information. Please refer to the relevant sections below for information that may apply to you:
California - Your California Privacy Rights: If you are a resident of California, please review the Additional Notice for California Residents for detailed California-specific privacy information, including the types of personal information we collect and your rights as a California consumer.
Nevada: Under Chapter 603A of the Nevada Revised Statutes, Nevada residents can opt out of the future sale of specific covered information collected by website operators. We do not sell personal information as defined by Chapter 603A. However, if you wish to submit such a request, you may do so via our Privacy Rights Request Center.
European Economic Area, United Kingdom, Switzerland, Australia, or New Zealand: If you are located in the European Economic Area (“EEA”), United Kingdom, Switzerland, Australia, or New Zealand, or engage with [Your Company Name] operations in those regions, please consult the Privacy Disclosures for the European Economic Area, United Kingdom, Switzerland, Australia, and New Zealand. These disclosures cover the types of personal information we collect, the lawful bases for processing your data, how cookies are used when accessing our Site, and your rights regarding your personal information.
1. INFORMATION WE COLLECT AND HOW WE USE IT
We gather personal information about you as part of your interaction with our Service. This includes information you provide directly when using the Service, data obtained from third-party sources, and information automatically collected through tools like cookies and similar technologies.
Information You Provide
We collect personal information directly from you in connection with your use of our Service. The types of information we collect include:
Account Information. When you create an account, we collect details such as your phone number, gender, email address, username, and display name. We may also gather your preferences, such as content settings (e.g., opting to view adult content) and Members you have blocked. This information is used to manage your account, deliver relevant services, communicate with you about your account and the Service, and provide customer support.
Creator Applications. If you apply to become a Creator on our Platform, we may collect the information you provide during the application process. This may include the name of the Creator who referred you, your full name, date of birth, email address, Social Security number or Tax ID, mailing address, bank details, EIN/business tax ID, and government-issued identification (e.g., driver’s license or passport). We use this information to verify your identity, set up and manage your Creator account, and communicate with you.Â
Identity Verification Information. To verify your identity and protect against fraud, we may utilize third-party services, such as Ondato. This may involve submitting your name, date of birth, address, email, phone number, government ID, and a selfie image. Persona may use biometric and machine learning technologies to authenticate your identity documents and ensure your selfie matches the ID. While Persona processes the biometric identifier, we only receive verification results, extracted information from your ID, and your selfie image. Biometric data is not used, disclosed, or retained for commercial purposes, and Persona handles it in accordance with our agreements. For more on Persona’s practices, please refer to their Privacy Policy here.
Purchase Information. If you buy paid content on the Platform, we collect details about your purchases to deliver the content and recommend similar items of interest. We also track your balance and usage of any credits associated with the Service.
Payment Information. When you purchase credits or other services, your payment details, including card information, are handled by third-party payment processors (e.g., Inovio Payments, LLC). Payment processors collect and retain payment data per their own privacy policies, which you can review here.
Creator-Generated Content. As a Creator, you may upload videos, photos, messages, and other content to our Platform. We collect this information to support your uploads and comply with applicable policies. Third-party services may assist in reviewing Creator content.
Chat Interactions. If you communicate with a Creator via our chat feature, we collect the information you share, including any personal details disclosed in the conversation.
Live Chat and Live Streams. For live, one-on-one sessions or live-streamed events, we may collect and store visual and audio data, such as video, photographs, and messages, to ensure compliance with our Acceptable Use Policy. Monitoring and storage are conducted with the support of third-party service providers.
Marketing Emails. When you subscribe to our updates, we collect your email, preferences, and interests to send promotional content about our products and services. To opt-out, follow the unsubscribe instructions in the email. Note that certain communications (e.g., account-related notifications) cannot be unsubscribed from.
Communications. If you contact us via email, phone, or any other medium, we collect the details you provide (e.g., name, email address, phone number). With your consent, phone conversations may be recorded for support and quality purposes.
Events, Surveys, and Promotions. If you participate in events, surveys, or promotional activities, we collect the information you submit (e.g., contact details, demographic information). This data is used to facilitate the event or promotion and inform you about similar opportunities.
Employment Applications. If you apply for a position with us, we collect details such as your contact information, education and work history, and any other details you choose to provide. This information is used to evaluate your application and facilitate onboarding.
You may choose whether or not to provide certain personal information. However, some information (e.g., your name, address, or payment details) may be required to deliver specific services. If incomplete or inaccurate information is provided, we may be unable to fulfill your request or provide the relevant service.
Automatic Data Collection
Like many digital platforms, we, along with our third-party providers and partners, automatically gather certain personal information when you visit or interact with our website and other online services. This includes:
User Content: This encompasses content you share on the Service, such as your interactions with other users, photos, videos, and any additional content you post through features like in-app messaging or chat (“User Content”). To share photos or videos, we may request access to your device’s camera and/or photo library with your consent. You can manage these permissions through your device’s “Settings” app. Note that we, along with our third-party providers, may monitor, record, and store User Content to ensure compliance with our Acceptable Use Policy. By using the Service, you consent to the recording, storage, and potential disclosure of your communications for the purposes outlined in our Acceptable Use Policy.
Log Data: We collect information such as your internet protocol (IP) address, operating system, browser type and ID, the URL you entered, referring pages or campaigns, date and time of your visit, time spent on our services, and any errors encountered during your session. Additionally, our systems may capture information you type into our websites or services, even if you do not submit it.
Analytics Data: This includes your navigation path to and through our services, as well as when you exit. It also tracks your activities and interactions, such as the links or items you view, click on, or engage with. For participants in the Affiliate Program, this includes affiliate member IDs, clicks on unique affiliate links, and subscriptions or purchases made through those links (“Clickstream Data”). Emails we send may also include tracking pixels to indicate if and when you open our emails, how many times they are read, and whether links within the email are clicked. This data helps us improve the relevance of our emails, measure the effectiveness of marketing campaigns, and confirm receipt of important administrative messages.
Location Data: Based on information like your IP address within the Log Data, we may infer your general geographic location.
For details about how we and our partners use cookies and similar technologies to collect information automatically, and the options available to you for managing these practices, please refer to the How We Use Cookies and Other Tracking Technologies section below.
Information from Third-Party Sources
We may receive personal information about you from our business partners, service providers, and other external sources, which we may combine with data collected directly from you. These third parties may include website and service operators, payment processors, and marketing affiliates. The information we receive can include contact details, demographic data, and insights about your communications and related activities. We use this information to manage and enhance our services, facilitate your subscriptions, and support marketing initiatives.
Identity Verification: To verify your identity and protect against fraud, we may use third-party identity verification services. This process may involve confirming details such as your name, email address, or government-issued identification. We use this information solely for security purposes and to ensure the integrity of our Service.
Information from Other Sources: We may collect additional information from external sources, including third-party data providers, other customers, or public databases. This information is combined with the data we collect directly from you and is handled in accordance with this Privacy Notice. We use this information to provide and maintain the functionality of the Service, improve your experience, and communicate with you, such as sending emails about products or services that may interest you.
Other Uses of Personal Information
In addition to the uses detailed above, we may collect and utilize personal information for the following purposes:
To operate and manage the Service, ensuring its features and functionality are delivered effectively;
To communicate with you and address your inquiries, including responding to questions, notifying you about changes to the Service, and discussing account-related matters;
To support marketing and promotional efforts by sharing updates, offers, and information about products or services that may interest you;
To conduct analytics and research aimed at improving and enhancing our Service;
To uphold our Terms of Use, resolve disputes, meet our obligations, protect our rights, and safeguard the interests of our business and third parties;
To comply with legal and contractual requirements or obligations;
To fulfill any specific purpose for which you have provided personal information; and
For any other lawful purpose or any purpose for which you provide explicit consent.
2. HOW WE SHARE PERSONAL INFORMATION
We may share, disclose, or grant access to your personal information with third parties in the following ways:
Service Providers: We work with third-party contractors and service providers who perform services on our behalf under reasonable confidentiality agreements. These services may include payment processing, identity verification, web hosting, technology support, email communication, content moderation (if applicable), analytics, data storage, and web or video hosting.
Business Partners: Personal information may be shared with our business partners for commercial purposes, such as promoting their products or services. Additionally, we may share your information with third parties offering products or services we believe you might find valuable.
Online Advertising Partners: We collaborate with advertising networks and allow them to collect information directly from our website to enable targeted advertising. These partners, such as search engines and social media platforms, may serve ads to you or groups with similar interests or demographics. For more details, including how to opt out of interest-based advertising, refer to the Third-Party Tracking and Online Advertising section below.
Affiliated Companies: We may share your personal information with companies and brands owned or controlled by us, as well as those under common ownership. These entities will use your information as described in this Privacy Notice.
Corporate Transactions: In the event of a sale or transfer of some or all of our business or assets (including shares), or as part of a merger, acquisition, bankruptcy, dissolution, reorganization, or similar proceedings, your information may be transferred. We will take reasonable measures to ensure that any transferred information is handled in line with this Privacy Notice.
Legal Obligations: Personal information may be shared with third parties when required by law, subpoena, or when we reasonably believe it is necessary to:
(a) comply with legal obligations or respond to law enforcement requests,
(b) enforce our Terms of Use or agreements, protect the Service's security, prevent fraud or illegal activities, or minimize harm or financial loss, or
(c) protect the rights, property, or safety of our users, employees, or others.
With Your Consent: We may disclose your personal information publicly or with third parties when you provide explicit authorization.
3. CONTROL OVER YOUR INFORMATION
Email Communications: We may periodically send you emails about updates to our Service, new products or services, organizational notices, or promotional offers from us or third parties that we believe may interest you. To unsubscribe from these emails, click the “unsubscribe” link included in the footer of the email. Please note that certain service-related communications, such as account verifications, transaction confirmations, or technical and legal notices, are essential and cannot be unsubscribed from.
Push Notifications: You can manage and stop push notifications from us by updating your preferences in your device’s notification settings for iOS or Android.
SMS Text Messaging: You can opt out of receiving promotional SMS text messages at any time. However, this will not affect non-promotional SMS texts directly related to your use of the Service, such as security verification codes for account login. To opt out of promotional messages, reply STOP to any of our promotional texts. For further details, refer to our Terms of Use.
Modifying Account Information: If you have an account with us, you can update certain details, such as your contact information, via the “settings” section on our Site. For requests to access, correct, or delete your personal information, please contact us using the email provided in the Contact Us section below. We will review and respond to your request, which may require additional information to verify your identity. While we will make reasonable efforts, we cannot guarantee that all requests will be fulfilled.
4. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES TO COLLECT INFORMATION
We, along with our third-party partners, automatically collect certain types of usage information when you visit our Site, interact with our emails, or engage with our services. This data is typically collected using various tracking technologies, including cookies, web beacons, embedded scripts, location-based technologies, file information, and similar tools (collectively, “tracking technologies”).
Through these tracking technologies, we and our partners gather usage and device information, including:
Device and Software Information: This may include your IP address, browser type, internet service provider, device type/model/manufacturer, operating system, date and time stamp, and unique identifiers such as a persistent device ID or Ad ID. We may also collaborate with third-party partners who use technologies, including statistical modeling, to identify and communicate with you across multiple devices.
Mobile-Specific Information: When accessing our services via a mobile device, we may collect unique identifiers like a UDID, IDFA, or Windows Advertising ID, as well as information about your mobile carrier, device type, operating system, and, in some cases, approximate location derived from data like your IP address.
Usage and Access Information: This includes details about your interactions with our services, such as the website you visited before ours, the pages you view, the links you click, purchases made via affiliate links, email interactions (e.g., whether you open our emails or click links), and whether you use our services across multiple devices.
Analytics Data: We may use analytics tools like Segment and Snowflake to measure traffic, usage patterns, and user demographics. For more details about their data practices, visit Snowflake’s Privacy Policy.
How We Use Tracking Technologies
The data collected through tracking technologies is used to:
(a) Remember your preferences so you don’t need to re-enter information during your visit or subsequent visits;
(b) Deliver personalized content and targeted advertising;
(c) Identify you across multiple devices for consistent service;
(d) Provide, monitor, and improve the effectiveness of our services;
(e) Measure aggregate metrics such as visitor numbers, traffic, and demographic trends;
(f) Diagnose and address technical issues; and
(g) Plan and enhance the functionality of our services.
Managing Cookies and Tracking Technologies
If you prefer not to accept cookies, most browsers allow you to:
(i) Adjust settings to notify you when a cookie is received, giving you the option to accept or decline;
(ii) Disable existing cookies; or
(iii) Configure the browser to reject cookies automatically.
Please note that disabling cookies may impact your experience, as some features and services may not function properly. Depending on your device and operating system, you may also be able to manage cookies and tracking technologies by modifying your browser or device settings. While these tools may not block all cookies, you can:
Set email options to prevent automatic image downloads, which may include tracking technologies;
Limit interest-based advertising by enabling options like “Limit Ad Tracking” (iOS) or “Opt-Out of Interest-Based Ads” (Android).
5. LINKS TO THIRD-PARTY WEBSITES AND SERVICES
For your convenience, our Service may include links to third-party websites or services that are not owned, operated, or controlled by us. We are not responsible for the privacy practices, content, or operations of these third-party websites or services. Any information you provide or activities you engage in while using those websites or services are governed by their respective policies, not ours.
Your use of any third-party website or service is at your own risk, and we strongly encourage you to review their privacy policies and terms of service before sharing any personal information.
6. CHILDREN’S PRIVACY
Our Service is not designed or intended for individuals under the age of 18. We do not knowingly collect or solicit personal information from anyone under 18, nor do we permit individuals under 18 to use our Service. By accessing or using our Service, you affirm that you are at least 18 years old.
If we discover that we have inadvertently collected personal information from someone under the age of 18, we will take prompt action to delete such information. If you believe that we may have received personal information from an individual under 18, please contact us so we can address the issue.
7. CHANGES TO PRIVACY NOTICE
We may update this Privacy Notice from time to time at our sole discretion. If we make material changes to how we handle your personal information, we will notify you through appropriate channels, such as sending an email to the primary address associated with your account, displaying a prominent notice on our Site, or using other suitable methods.
We encourage you to review this Privacy Notice periodically to stay informed about how we protect your information. Unless stated otherwise, all updates will take effect on the date they are published.
 9. CONTACT US
For additional inquiries about this Privacy Notice, please send us an email at (email ) or contact us at: (Address)
ADDITIONAL NOTICE FOR CALIFORNIA RESIDENTS
This Additional Notice for California Residents (“CA Disclosures”) supplements the information in our Privacy Notice and applies specifically to individual residents of California (“consumers” or “you”).
These CA Disclosures provide additional details about how we collect, use, disclose, and otherwise process the personal information of California residents, both online and offline, as required under the California Consumer Privacy Act of 2018 (“CCPA”). Unless otherwise stated, terms used in these CA Disclosures have the same meanings as defined in our Privacy Notice or as specified under the CCPA.
For the purposes of these CA Disclosures, “personal information” is defined by the CCPA and excludes information that is publicly available, deidentified, aggregated, or otherwise outside the scope of the CCPA. This section does not apply to information related to our employees, contractors, or other personnel.
1. COLLECTION AND USE OF PERSONAL INFORMATION
We collect personal information from and about you for various purposes, as outlined in the Information We Collect and Our Use section of our Privacy Notice.
In the past 12 months, we have collected the following categories of personal information:
Identifiers: Such as your first and last name, email address, username, postal address, display name, physical characteristics, date of birth or age, driver’s license number, passport number, account number, or other similar identifiers.
California Customer Records: Including payment information.
Commercial Information: Such as records of services purchased, obtained, or considered.
Internet/Network Information: Including device information, logs, and analytics data.
Geolocation Data: Such as approximate location data based on your IP address or other sources.
Sensory Data: Including audio and visual information collected during phone calls, when you upload Creator-Generated Content, or when using our Live Chat feature.
Professional/Employment Information: Such as details provided in job applications, resumes, or other professional materials.
Biometric Information: Information submitted to authenticate your identity documents and verify your identity.
Inferences: Insights about your preferences and interests based on your interactions with our services.
Other Categories: Including User Content created and shared publicly on the Service, as well as any special badges (e.g., VIP Badges) earned or purchased.
We collect this information directly from you, publicly available sources, and through service providers and other third parties, such as single sign-on partners, advertisers, creators, and information providers.
For more details about the personal information we collect and the methods of collection, please refer to the Information We Collect and Our Use section of our Privacy Notice.
2. RECIPIENTS OF PERSONAL INFORMATION
We share personal information with third parties for business purposes. The categories of third parties with whom we may share your personal information include:
Affiliated Brands and Companies: Other brands and affiliates within our corporate family.
Service Providers and Advisors: Third-party contractors and advisors who perform services on our behalf, such as payment processing, hosting, and marketing.
Analytics Providers: Partners that help us understand and improve the usage and performance of our services.
Government Agencies or Regulators: Entities to which we may disclose information as required or permitted by law.
For more information about how we share personal information with third parties, please refer to the How We Share Personal Information section of the Privacy Notice.
3. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, you may have the following rights regarding your personal information, subject to certain legal limitations:
Right to Know: You may request the following details about the personal information we have collected and disclosed in the past 12 months, upon verifying your identity:
The specific pieces of personal information we have collected about you.
The categories of personal information we have collected.
The categories of sources from which the personal information was collected.
The categories of personal information disclosed to third parties for a business purpose, and the categories of recipients of that information.
The categories of personal information sold (if applicable) and the categories of third parties to whom the information was sold.
The business or commercial purposes for collecting or selling the personal information.
Right to Request Deletion: You may request the deletion of personal information we have collected from you, subject to certain exceptions.
Right to Opt Out of Sales: You may opt out of the sale of your personal information to third parties, now or in the future.
Additionally, you have the right to be free from discrimination for exercising any of these rights. However, please note that if exercising your rights affects our ability to process your personal information (e.g., a deletion request), we may no longer be able to provide certain products or services to you or interact with you in the same way.
Submitting Requests
To Exercise Your Right to Know or Right to Deletion
If you wish to exercise your right to know or right to deletion, you can submit a request by:
Visiting our Privacy Rights Request Center, or
Calling (866) 758-7448
Before we process your request, we will need to verify your identity and confirm that you are a California resident. To verify your identity, we may require you to either successfully authenticate your account or provide sufficient information that matches the details we have in our systems. This verification process may involve requesting additional personal information from you, such as your email address, physical address, order number, or the date of your last interaction with customer service.
In some instances, we may decline a request to exercise the right to know or right to deletion, particularly if we are unable to verify your identity or if the request conflicts with legal or business requirements.
To Exercise Your Right to Opt-Out of Personal Information Sales
Unless you choose to exercise your Right to Opt-Out of Personal Information Sales, we may share personal information with third parties in exchange for monetary or other valuable consideration. These third parties may use your information for their own purposes, as outlined in their respective privacy policies, which could include reselling this information to additional parties. Such third parties may include:
Business Partners: We may share personal information, such as Identifiers and Internet/Network Information, with our business partners for commercial purposes, including promoting their products or services. Additionally, we may share your personal information with other third parties offering products or services we believe may interest you.
Third-Party Advertising Networks, Social Media Platforms, and Other Businesses: These entities may collect and use your personal information (such as Internet/Network Information, Commercial Information, and Inferences) directly through cookies or tracking technologies when you interact with our websites, apps, or other digital services. This data is often used for purposes like analyzing and optimizing our services, delivering personalized content, or targeting advertisements on our Site, other websites, or mobile apps. These activities may include reporting, attribution, analytics, and market research.
Exercising Your Right to Opt-Out
You do not need to create an account to exercise your Right to Opt-Out of Personal Information Sales. However, we may request additional personal information, such as your name, email address, or postal address, to verify your identity in our system and ensure compliance with your request. Any personal information provided in connection with an opt-out request will only be used to process and document the request. If you choose not to provide sufficient information, we may only be able to process your request to the extent we can identify you in our systems.
Cookies Opt-Out (Do Not Sell My Personal Information): To opt out of the use of cookies and tracking technologies for analytics or targeted advertising purposes, visit the Cookie Preferences section on your settings page.
Opt-Out of Selling or Sharing Personal Information: To exercise your right to opt out of the sale or sharing of your personal information (such as your name, email address, or postal address) with third parties for their direct marketing or other commercial purposes, please visit the Privacy Rights Request Center or contact us directly.
Authorized Agents
California residents may designate an authorized agent to submit requests to know or delete personal information on their behalf. Authorized agents may submit such requests using the methods outlined in this Notice. To verify the agent’s authority to act on the consumer’s behalf, we require the following:
For General Requests (Know or Delete Personal Information):
A valid power of attorney executed in accordance with California law, or
Sufficient evidence demonstrating that the consumer has:
Provided signed permission authorizing the agent to act on their behalf.
Verified their own identity directly with us, following the procedures set forth in these CA Disclosures.
Directly confirmed with us that the agent is authorized to make the request on their behalf.
For Requests to Opt-Out of Personal Information "Sales":
Signed documentation proving the agent has permission to act on behalf of the consumer to submit an opt-out request.
We reserve the right to request additional information to verify the identity of the consumer and/or the agent’s authority to act on their behalf, as necessary to comply with California law.
Financial Incentives
We may offer financial incentives to consumers who permit us to collect and retain certain personal information, such as Identifiers (e.g., name and email address) and Commercial Information (e.g., purchase history). These incentives could result in differences in the prices or services offered to consumers, including benefits such as payments (e.g., free products or services) or reduced prices for goods and services (e.g., discounts and promotions). For instance, we may provide discounts or free products to new customers as part of a financial incentive program.
The material terms of any financial incentive program will be clearly explained in the program’s terms or within the details of the specific incentive offer.
Participation in financial incentive programs is completely optional, and you may withdraw at any time. To opt out and discontinue participation in an incentive program, follow the instructions in the program’s terms and conditions or contact us using the information provided at the end of this Notice.
Each financial incentive or price/service variation related to personal information collection and use is based on a reasonable and good-faith evaluation of the estimated value of such information to our business. This evaluation takes into account the value of the incentive provided and the potential revenue benefits derived from fostering customer loyalty and repeat business.
Privacy Disclosures for the European Economic Area, United Kingdom, Switzerland, Australia, and New Zealand
These Privacy Disclosures explain how we process your personal data when you access our Service from the European Economic Area (“EEA”), United Kingdom (“UK”), Switzerland, Australia, or New Zealand. Please read these Privacy Disclosures together with our Terms of Service ("TOS") before accessing or using the Service. Terms defined in our TOS, such as "Member" and "Creator," retain the same meaning when used in these Privacy Disclosures.
Personal Data
In these Privacy Disclosures, “personal data” refers to information relating to an identified or identifiable natural person.
Controller
[Your Company Name], Inc., a company incorporated under the laws of the United States, is the “controller” responsible for the processing of personal data in connection with our Service. As the controller, we determine how your personal data is used.
Registered Address:
Featurefold
8424 Santa Monica Blvd, Suite A #770
West Hollywood, CA 90069
Contact Information:
Email: featurefold@gmail.com
Mailing Address: Featurefold
8424 Santa Monica Blvd, Suite A #770
West Hollywood, CA 90069
For any questions regarding your rights, these Privacy Disclosures, our Privacy Notice, or general privacy matters, please contact our EU or UK representative. Ensure you reference [Your Company Name] in all correspondence.
EU Representative
Instant EU GDPR Representative Ltd.
Re: Featurefold
Office 2, 12A Lower Main Street
Lucan, Co. Dublin
K78 X5P8
Ireland
Email: contact@gdprlocal.com
UK Representative
GDPR Local Ltd.
Re: Featurefold
1st Floor Front Suite, 27-29 North Street
Brighton, England
BN1 1EB
Note for Residents of Australia and New Zealand
For residents of Australia and New Zealand, the following adjustments apply for interpreting these Privacy Disclosures under applicable privacy laws (specifically the Privacy Act 1998 (Cth) for Australia and the Privacy Act 1993 and Privacy Act 2020 for New Zealand):
The term “personal data” is equivalent to “personal information” as defined under the respective National Acts.
Terms like “controller,” “processor,” “data subject,” and “processing” should be understood as their closest equivalents under the National Acts or interpreted to achieve similar substantive outcomes as under UK or EEA privacy laws.
1. PERSONAL DATA WE COLLECT FROM YOU WHEN YOU USE THE SERVICE, AND HOW WE USE IT
We collect the following categories of personal data that you voluntarily provide when using the Service:
Account Information: Personal data you provide when registering for an account, such as your phone number, email address, handle, gender, display name, and content preferences.
Creator Information: If you are invited to become a Creator on our Platform, we collect details associated with your invitation, including your first and last name, date of birth, email address, Social Security number or Tax ID, address, banking details, and EIN/business tax ID.
Referrals: If a Creator invites another Creator to the Service using an invite link, the referred Creator's account will be associated with the referring Creator's account.
Identity Verification Information: To verify your identity and protect against fraud, we use third-party identity verification services, such as Persona. This process may involve submitting your name, birthdate, address, phone number, email address, government ID number, copies of identification documents, and a selfie. Persona may use tools like facial recognition and optical scans to confirm your identity by comparing the selfie with the ID provided.
Payment Information: When you make a purchase through the Service, we collect payment information, such as payment card details, through secure third-party processors.
Transaction Information: We collect details about your transactions on the Service, including purchases, subscription balances, and, if you are a Creator, information about the content and subscriptions you offer.
User-Generated Content: When you upload content to the Platform (e.g., profile images, bios, videos, or other Creator content), we collect visual and audio information associated with that content.
Live Chat, Live Streaming, and Direct Messaging: If you send or receive direct messages ("Direct Messaging"), participate in live one-on-one video chats ("Live Chat"), or host live video streams for multiple users ("Live Streams"), we collect visual and audio data from these interactions.
Marketing Emails: If you sign up for updates, we collect your email address and preferences to send you news, alerts, and promotions. You can unsubscribe from promotional messages by following the instructions in the email. Note that service-related emails (e.g., account verifications or transaction confirmations) cannot be unsubscribed from.
Communications: When you contact us via paper, electronic form, or phone, we collect your name, email address, phone number, and any additional personal data you provide. Phone conversations may be recorded with your consent.
Events, Surveys, and Promotions: If you participate in events, surveys, contests, sweepstakes, or other promotional activities, we collect the information requested during registration or participation.
Additional Information
The table in Annex 1 provides more details about the personal data we collect, how we use it, the legal basis for processing, and the recipients of this data.
When collecting personal data, we will indicate if the data is mandatory or optional. Certain information, such as your name, address, payment details, and service preferences, may be essential for accessing specific features. If you choose not to provide required information or provide incomplete/inaccurate data, we may be unable to deliver certain services or respond to your inquiries.
2. INFORMATION WE COLLECT FROM OTHER SOURCES
We may collect personal data about you from the following sources:
Social Media: If you interact with our Service through social media platforms—such as clicking a social media icon on our site, sharing content, following our account, or commenting on our pages—we may receive information from the social network. This information can include your profile data, profile picture, username, user ID associated with your social media account, gender, age range, language, country, and any other details the social network allows third parties to access based on your privacy settings.
Information From Other Members: Other Members may provide personal data about you, such as when they post comments referencing you or share content featuring you.
For more details about the categories of personal data we collect, how we use it, and the legal basis for processing it, please refer to the table in Annex 1.
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1. INFORMATION WE COLLECT ABOUT YOU AUTOMATICALLY
We also collect personal data indirectly through your interactions with the Service and your devices. This includes:
(a) Usage Information: Data about the features you use, subscriptions you sign up for, and pages you view on the Service.
(b) Device Information: Information about the device you use to access the Service, such as your IP address, device identifier, device type, model, and manufacturer.
(c) Usage Patterns: Data about how you interact with the Service, including how frequently you use it and your language settings.
We use this information to provide the features and functionality of the Service, monitor and improve performance, and develop new features and services.
If you register for the Platform using a referral link provided by a user participating in our Affiliate Program, we will associate your account with that referral link so the referrer can claim their reward per the Affiliate Program Terms.
For additional details about the categories of personal data we collect automatically, how we use it, the legal basis for processing, and recipients of this data, please refer to the table in Annex 2.
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Combining and Anonymizing Data
We may link or combine the personal data we collect directly from you with data collected automatically or from other sources.
Additionally, we may anonymize and aggregate personal data (removing any identifiers that link it to you). Anonymized data may be used for purposes such as IT system testing, research, data analysis, and improving the Service.
3. HOW LONG WILL WE STORE YOUR PERSONAL DATA
Except as outlined below, we do not generally retain personal data after you close your account on the Service unless required to comply with applicable laws or if the data is necessary to address a complaint or legal claim.
We will retain the following types of information for up to 7 years after you close your account:
Identity Verification Information: Copies of identity documents provided for age verification and records of identity verification conducted.
Creator Information: Records of payments made to you and any agreements you entered into with other Creators.
Referrals: Details of amounts paid to you for referring another Creator, as outlined in our Referral Program Terms.
Creator-Generated Content: Retained if complaints were made about such content or if there is a potential legal claim related to it.
Live Chat, Live Streams, and Direct Messaging: Copies of any recordings or records of Live Chats, Live Streams, or Direct Messaging, retained in cases of complaints or potential legal claims.
Communications: Records of any complaints made by or against you in communications with us.
Data retained under these conditions will only be used as necessary to fulfill legal, regulatory, or operational requirements and will be securely deleted once it is no longer needed.
5. RECIPIENTS OF PERSONAL DATA
We may share your personal data with the following parties, as required for the purposes outlined in Annex 1 and Annex 2:
Service Providers and Advisors:
We may share your personal data with third-party vendors and service providers who perform services on our behalf or assist us with operational needs. These services may include professional services (e.g., legal and accounting), mailing, email or chat support, fraud prevention, web hosting, and analytics. Details of the service providers that may receive personal data are provided in Annex 1 and Annex 2. We may also share your data with third-party vendors as outlined in our Monthly Compliance Report Policy.
Affiliates:
Your personal data may be shared with companies under common ownership or control with [Your Company Name], including subsidiaries and our ultimate holding company. These entities will use your personal data in accordance with this Privacy Notice.
Purchasers and Third Parties in Connection With Business Transactions:
Personal data may be disclosed to third parties in connection with a business transaction, such as a merger, sale of assets, reorganization, financing, or acquisition of all or part of our business.
Law Enforcement, Regulators, and Other Legal Obligations:
We may share your personal data with third parties when required to do so by law or when we believe it is necessary to:
Comply with legal obligations or respond to lawful requests from law enforcement agencies.
Detect and investigate illegal activities, security issues, or breaches of agreements, including our Terms of Service.
Protect the rights, property, or personal safety of [Your Company Name], its users, or others.
6. MARKETING AND ADVERTISING
From time to time, we may contact you to provide information about our services, including marketing messages and requests for feedback. Most of our marketing communications are delivered via email. We may also use the personal data we collect about you to tailor marketing messages and ensure they are relevant to your interests.
We will only send you marketing communications if you have given us your explicit consent. You can withdraw your consent at any time by:
Clicking the "unsubscribe" link at the bottom of our marketing emails, or
Updating your preferences on the Email Preferences page within the Platform.
Withdrawing your consent will not affect your ability to receive essential service-related communications, such as account notifications or transactional emails.
7. STORING AND TRANSFERRING YOUR PERSONAL DATA
Security
We employ appropriate technical and organizational measures to safeguard your personal data against accidental or unlawful destruction, loss, alteration, or damage. All personal data collected is stored on secure servers provided by our cloud hosting provider. We will never send unsolicited emails or contact you by phone to request sensitive information such as credit or debit card details or national identification numbers.
International Transfers of Your Personal Data
Your personal data may be transferred to and stored in countries outside your jurisdiction, where we and our third-party service providers operate. For users in the EEA, United Kingdom, Switzerland, Australia, or New Zealand, this may include transfers to and processing in the United States or other countries that may not offer the same level of data protection as your home jurisdiction.
When personal data is transferred internationally, we ensure that:
The receiving country is recognized as offering an equivalent level of data protection, or
Appropriate safeguards are in place, such as agreements incorporating standard contractual clauses adopted by the European Commission or approved by the UK Information Commissioner, which require the recipient to handle your personal data with protections equivalent to those in your jurisdiction.
Additionally, if required by applicable law or to protect the rights of [Your Company Name] or our users, we may disclose personal data to law enforcement authorities or regulators in any of our Supported Countries.
If you have questions about the safeguards used for international transfers, please contact us using the details provided at the beginning of these Privacy Disclosures.
8. PROFILING
We may analyze the personal data we collect about you to create a profile of your interests and preferences. This helps us provide you with information and communications that are more relevant to your needs. Where available, we may supplement this analysis with additional information about you obtained from external sources to enhance its accuracy and effectiveness.
Additionally, we may use your personal data to identify and mitigate risks, such as fraud or credit risk, to ensure the security and integrity of our services.
9. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
In accordance with applicable privacy laws, you have the following rights concerning the personal data we hold about you:
Right of Access:
You have the right to obtain:
Confirmation of whether, and where, we are processing your personal data.
Information about the categories of personal data we process, the purposes of processing, and how we determine retention periods.
Details about the categories of recipients with whom we may share your personal data.
A copy of the personal data we hold about you.
Right of Portability:
In certain circumstances, you have the right to receive a copy of the personal data you have provided to us in a structured, commonly used, and machine-readable format, or to request its transfer to another entity.
Right to Rectification:
You have the right to request the correction of any inaccurate or incomplete personal data we hold about you, without undue delay.
Right to Erasure:
In certain circumstances, you can request that we erase your personal data without undue delay, such as when continued processing is no longer justified.
Right to Restriction:
You may request that we limit the purposes for which we process your personal data, for example, when you contest the accuracy of the data or object to its processing.
Right to Withdraw Consent:
If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
Right to Object:
You can object to processing based on our legitimate interests if there are grounds relating to your particular situation.
You can object to marketing activities for any reason, and we will honor your request.
If you wish to exercise any of these rights, please visit our Privacy Rights Request Center.
Due to the sensitive nature of data processing, we may require you to verify your identity before acting on your request.
Filing a Complaint
If you believe your rights have been violated, you have the right to lodge a complaint with your local data protection authority:
European Union: Find your local data protection authority here.
United Kingdom: UK Information Commissioner’s Office (ICO).
Switzerland: Swiss Federal Data Protection and Information Commissioner (FDPIC).
Australia: Office of the Australian Information Commissioner (OAIC).
New Zealand: Office of the Privacy Commissioner of New Zealand.
10. COOKIES AND SIMILAR TECHNOLOGIES USED ON OUR SERVICES
Our Service uses cookies and similar technologies, such as pixels and Local Storage Objects (LSOs) like HTML5 (collectively, "cookies"). Cookies are small pieces of data that are stored on your device to help us distinguish you from other users, personalize your experience, and save your preferences (e.g., phone number or language selection). Cookies also enable us to monitor and analyze how you interact with our Service, allowing us to improve its functionality and provide targeted advertisements in collaboration with our advertising partners.
Types of Cookies We Use
Strictly Necessary Cookies:
Essential for the operation of our Service. These cookies enable secure logins and help maintain your session while you browse.
Analytical/Performance Cookies:
Used to measure and analyze visitor behavior, such as tracking how users navigate the Service. This information helps us improve usability and ensure users find what they need.
Functionality Cookies:
Enable personalization by remembering your preferences when you return to the Service, such as your language or region.
For a detailed list of the cookies used on our Service, please refer to Annex 3.
Your Cookie Preferences
Except for strictly necessary cookies, we will only place cookies on your device with your consent. When you first access our Service, you will be asked to specify which types of cookies you agree to receive. You can update your cookie preferences at any time through the Cookie Preferences page on the Platform.
Most web browsers also allow you to block or delete cookies. However, depending on your device or operating system, you may not be able to block all cookies or similar tracking technologies (e.g., LSOs). Please note that refusing all cookies may limit your ability to access certain features of our Service.
Managing Cookie Settings
To adjust your browser’s cookie settings, you can follow the links below or use your browser’s "Help" menu for more information:
For more general information about cookies and similar technologies, visit www.allaboutcookies.org or the Network Advertising Initiative at www.networkadvertising.org.
Please note that deleting or blocking cookies may not effectively disable all tracking technologies, such as LSOs like HTML5.