The company and Platform

FDH Enterprises Limited and its affiliates ("fawnstars") value your privacy and are dedicated to safeguarding the personal information we handle about you. fawnstars is a social networking platform that allows users known as "Creators" to share and monetize their original content, while also giving them the ability to subscribe to and view the content of other Creators. Additionally, fawnstars enables "Fans" to subscribe to and view the content created by these Creators.

About the policy

This privacy policy ("Policy") provides an explanation of our practices regarding the handling of personal data for our Creators and Fans. Certain sections of the Policy are specifically directed towards Creators, while others are aimed at Fans. It also applies to the processing of personal data for individuals featured in content uploaded by a Creator ("Content Collaborators"), as well as the processing of personal data related to our business relationships.

We process your personal data when you utilize our platform, www.fawnstars.com ("Platform"), and when we provide services through our Platform. Additionally, we process your personal data when you engage with us on social media platforms such as Twitter and Instagram, or through other means. In this Policy, we collectively refer to these activities as the "Services." As a "data controller," we are responsible for determining the purposes and methods of processing personal data about you.

Please take the time to review this Policy in order to understand how we process your personal data in connection with the Services. By using our Services, you acknowledge that you have read and understood this Policy.

Personal Data

The term "personal data" refers to information that can identify, describe, or be associated with a specific individual or household, either directly or indirectly. Furthermore, we may collect data that cannot identify you or is not linked to you in any way, such as de-identified, aggregated, or anonymised information. This type of data does not qualify as personal data and is not governed by this Policy.

Changes

Notifying us of any changes It is crucial that the personal data we have about you is accurate and up to date. Please inform us if there are any changes to your personal data during your relationship with us. You can update or correct your information through your account settings on our platform. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes at any point during your relationship with us. Updates or corrections can be made through your account settings on our platform.

Policy for over 18

This Policy is given as an additional document to our Terms and Conditions that govern your usage of our Platform and the Services. Our Services are exclusively meant for individuals who are 18 years old or above. Individuals under 18 years old are prohibited from using the Services. By utilising the Services, you confirm that you are 18 years old or older.

Third-parties

Our Platform may contain links to platforms, plug-ins, and applications from third parties. By clicking on these links or enabling these connections, you may be giving third parties the ability to collect or share personal information about you. Please note that we are not responsible for and this Policy does not apply to the content, security, or privacy practices of these other platforms, plug-ins, or applications. We strongly encourage you to review the privacy and cookie policies/notices of these third parties to understand how they may use your personal information.

Providing personal data

In order to grant you access to the Services or specific features and functionalities, we must gather specific personal information from you. This is in accordance with our agreement, outlined in our Terms and Conditions. Additionally, we are obligated to handle certain personal data in compliance with relevant laws. It is important to note that if you choose not to provide the requested personal data, we may be unable to grant you access to the Services or specific features and functionalities.

Updates

We reserve the right to modify this Policy periodically, with any changes becoming effective once we publish the updated Policy on our Platform. We will make reasonable efforts to inform you if significant changes are made to this Policy, such as sending you a notification or a message through your account on our Platform.

Personal data

We handle various types of personal data about Creators and Fans, either through our own processing or through third-party providers acting on our behalf.

Creators:

Signup

• Full name
• Profile Name
• Encrypted Password
• Country of residence
• Email address

Financial

• Pay-out country
• Business or corporate entity for tax purposes
• US Creators only – Social Security No., W-P, 1099-MISC & 1099-NEC
• Earnings
• Pay-out requests
• Revenue earned into your account

Analytics

• IP Address
• Internet Service Provider
• Device type
• Name and version browser

On-Boarding

• Our third-party providers require a government identity document provided by you, which will be copied.
• A "Liveness image" from you, which will be used for identification and verification purposes
• The third-party age and identity verification process will provide results indicating whether you have passed or failed, along with the reason for any failures.
• Additionally, there will be metadata associated with the verification process, such as the start and finish time.
• A social media account or personal platform address from a third party to verify your age and identity, as well as to gain a better understanding of the content you are likely to share on our platform.

Accounts

• Profile Name
• Avatars
• Subscriptions, subscribers and referral
• Published posts
• Comments, chats and customer service reports and questions

Fans:

Sign up

• Full name
• Username
• Encrypted Password
• Country of residence
• Email address

Financial

• Card payment details
• Billing address
• Tokens added to your wallet

Analytics

• IP Address
• Internet Service Provider
• Device type
• Name and version browser

On-Boarding

• If we need to verify the age and identity of Fans through third-party providers in certain locations, you will need to provide a copy of your government-issued identification document.
• In locations where third-party age estimation or age and identity verification of Fans is required. A "Liveness Image" from you, which will be used for identification and verification purposes
• The third-party age and identity verification process will provide results indicating whether you have passed or failed, along with the reason for any failures.
• Additionally, there will be metadata associated with the verification process, such as the start and finish time.

Accounts

• Username
• Avatars
• Subscriptions
• Comments, chats and customer service reports and questions

Fans and Creators

We utilise cookies in situations where they are necessary, such as allowing you to browse the Services and access specific pages of the Platform. Additionally, with your consent, we will employ cookies for the following purposes:

• Performance on the Platform: This involves analyzing how users interact with the Platform in order to enhance the Services. If you are a Creator, it also allows us to recognize when you have referred another Creator through your unique referral code.
• Platform functionality: Cookies are used to save your logged-in status.

Currently, we do not employ any cross-site tracking technologies, nor do we sell or share any personal data collected about you for cross-context behavioural advertising.

On-boarding procedures

Creators

We have implemented procedures to guarantee that all individuals who create content on our platform meet the following criteria: They are at least 18 years old, and they verify their identity. Before you can create a creator account, we will:

• Request that you provide personal data as a creator.
• Verify your country of residence to ensure legal access to our platform and services.
• Ask for financial data. This information is necessary in order to make payments to creators for their content and to allow creators to access their earnings through our platform. The collection of financial data also serves as a means of verification and anti-fraud measure.
• Verify that you have not been previously prohibited from utilizing the Platform and our Services

We will request that you undergo a verification process for age and identity through a third-party service:

• This process entails the third-party provider collecting a liveness image and a photo of a government-issued identification document (both provided by you).
• The third-party then utilises Face Recognition Data to compare the two images and digitally confirm your age and identity.
• We do not gather, receive, possess, or have access to any Face Recognition Data acquired or processed by our third-party providers during this process.
• In accordance with applicable law, we receive Third-Party On-boarding Data and specific Technical Data from our third-party providers, to maintain a record of the age and identity verification process.

Fans

We have implemented procedures to ensure that: All individuals using the Platform are at least 18 years old; and individuals in certain locations verify their identity. Before you can create a user account, we will:

• Request that you provide personal data as a fan
• Verify your country of residence. This verification is necessary to ensure legal access to the Platform and its services.
• Ask you to provide financial information, which is required for fans to purchase Tokens
• Financial data is also collected as a means of verification and anti-fraud measure.
• Guide you through a third-party process for age confirmation. The specific process will depend on your location, the third-party provider and new legislation.

Age and identity verification conducted by an independent party. In specific jurisdictions, it is mandatory for us to authenticate the age and identity of our users so we need to take additional steps.

Your personal data

We obtain your personal information from various sources, which can be categorised as follows:

• Directly from you: This includes information that you provide to us when you open an account and use our services, update your personal details in your account, or communicate with us (such as User Data and Account Data).
• Automatically or indirectly from you: This refers to information that we collect through your use of our services (such as Transaction Data, Technical Data, and Usage Data).
• From our service providers: In certain cases allowed by applicable law, we receive Third-Party On-boarding Data and specific Technical Data from third-party providers who verify age and identity.

Personal Data Sharing

We may need to share your personal data with certain third parties. These include our trusted service providers who assist us with:

• IT support, payment processing, customer support, content moderation, and age verification services.

We also work with professional advisors such as:

• Legal experts, bankers, auditors, accountants, consultants, and insurers who may require access to your personal data in order to provide their services. Rest assured that we only share your information with these parties when it is necessary for our legitimate interests and to support the functionality of our business.
• Authorities, regulators, and organisations of relevance: In response to requests from governmental entities (including law enforcement and tax authorities), regulatory bodies, and select non-governmental organizations, your personal data will be shared. These recipients will utilise your personal information within the scope of their regulatory, law enforcement, charitable, or not-for-profit functions. The legal basis for sharing your personal data with these recipients is either the necessity to comply with a legal obligation that we are bound by, or it is necessary for our own or a third party's legitimate interests, or in the interest of the general public.

Lawful use of your personal data

We utilise personal information for, or based on, one or more of the subsequent legal grounds:

• Consent: Your consent is only requested in specific situations, including the processing of:
• Face Recognition Data by our third-party providers as part of the age and identity verification process for all Creators (and for Fans in certain locations);
• Age estimation captures (which may involve the use of Face Recognition Data) by our third-party providers for Fans in certain locations.
• Performance of a contract: By utilising the Services, you have entered into a contract with us through our Terms and Conditions, and we will process personal data to fulfil that contract and to enforce the terms of that contract.
• Legitimate interests: Personal data may be processed if it serves our or a third party's legitimate interests. This encompasses activities such as investigating and addressing reports submitted through our DMCA takedown procedure to safeguard the intellectual property rights of creators.
• Compliance with legal obligations: As a global company, personal data may be processed to comply with applicable laws, rules, and regulations in the locations where we operate.
• Task carried out in the public interest: Personal data may be processed when necessary for tasks undertaken in the public interest. This may involve reporting illegal activities to relevant law enforcement authorities, governmental agencies, and non-governmental organizations.

We will only utilise your personal data for the purposes for which it was collected, unless we reasonably determine that there is a need to use it for another purpose that is compatible with the original intention.

Rights regarding your personal data

You have specific rights concerning the gathering and handling of personal information. These rights can be exercised by reaching out to us using the contact information. In certain circumstances and with certain exceptions, you possess the following rights:

• Revoke your consent for the processing of your personal data: It is important to note that withdrawing your consent will not affect the legality of any processing that occurred prior to your withdrawal.
• Request knowledge or access to your personal data: You have the right to receive a copy of the personal data we hold about you and verify that we are lawfully processing it.
• Request the correction of your personal data held by us: If there are any incomplete or inaccurate personal details in our possession, you have the right to have them corrected.
• Request the deletion or removal of your personal data: You can ask us to delete or remove personal information if there is no legitimate reason for us to continue processing it. Additionally, if you have exercised your right to object to the processing, you may also request the deletion or removal. Please note that we may not always be able to fulfil your deletion or removal request due to certain legal circumstances.
• You have the right to request the limitation of processing your personal information. If you believe there are inaccuracies or have concerns about the processing of your data, you can ask us to temporarily suspend it.
• You can ask for the transfer of certain parts of your personal information to another party. Additionally, if we are processing your personal data based on legitimate interests and there is something specific about your situation that makes you want to object to the processing, you have the right to do so. We do not engage in automated decision-making that would have a significant legal impact on you.

Controlling your personal data

Modifying and deleting your personal information: If you hold an account with us, you have the ability to update your account settings on our Platform.

Controlling access to device information: You have the ability to manage the Services' access to your Technical Data through the "Settings" application on your device.

Opting out of email notifications: We send email notifications that are related to your account, such as updates for Creators when you gain a new subscriber, receive a new tip, or when someone renews their subscription with you. You have the option to opt-out of receiving certain types of email communications from us by adjusting your notification preferences on our Platform.

Alternatively, you can contact us via email using the provided contact details. Please note that there are certain automated email notifications that you cannot opt-out of, as they are necessary for providing the Services or required by applicable law. These may include account verification, transactional communications, and changes/updates to features, reports and complaints.

Retaining of personal data

We will retain your personal information for a duration that is reasonable and necessary to fulfil the purposes for which it was collected, as outlined in this Policy. After your account on the Platform has been deleted or deactivated, we typically keep personal data for a period of 6 months. It is important to note the following:

• If applicable law requires a shorter retention period, we will delete your personal information sooner.
• We may retain your personal data for a longer period if it is necessary to carry out the processing activities described in this Policy. For instance, this includes compliance with applicable laws and regulations (such as record-keeping and maintenance requirements in specific locations, financial and tax reporting obligations that can be up to 7 years). Additionally, if we receive a valid legal request pertaining to your account, such as a preservation order or search warrant, we may need to retain your personal data.
• To ensure the identification and reporting of illegal activity, safeguard the well-being of our users and third parties, and protect the rights and property of all parties involved (for example, in cases where there is a suspected violation of our Terms of Service and instances where users are banned from accessing the Platform), we may use your personal data.
• Additionally, your personal data may be utilized for legal proceedings, such as defending ourselves in litigation related to a claim concerning you. Furthermore, we may disclose your personal data to third parties, including law enforcement authorities, government entities, and non-governmental organisations), in response to their requests or investigations pertaining to your account. The retention of your personal data and the length of time it is kept will be determined on a case-by-case basis, taking into account the specific circumstances.

Questions and contact

If you have questions about privacy or any of the contents of this notice, please don’t hesitate to get in touch with us! 

You can email us at compliance@fawnstars.com