Naughty Creator Subscription Platform - PRIVACY POLICY

Last Updated: January 1, 2024

1. APPLICABILITY OF THIS POLICY (18+)
2. SOURCES OF PERSONAL DATA
3. THIRD-PARTY LINKS
4. USAGE OF YOUR PERSONAL DATA
5. SHARING YOUR PERSONAL DATA
6. CATEGORIES OF PERSONAL DATA
7. IF YOU CHOOSE NOT TO SHARE YOUR PERSONAL DATA
8. INTERNATIONAL USERS
9. OPTIONS FOR MANAGING YOUR PERSONAL DATA
10. INFORMATION ABOUT YOUR PERSONAL DATA RIGHTS
11. EXERCISING YOUR RIGHTS
12. RETENTION OF PERSONAL DATA
13. SECURITY OF PERSONAL DATA
14. SALES OF PERSONAL DATA
15. ASSISTANCE AND CONTACT INFORMATION

Naughty Creator is operated by NCreator OÜ. We are a limited liability company registered in Estonia, with company registration number 16772845 and we have our registered office address at Harju maakond, Tallinn, Lasnamäe linnaosa, Lõõtsa tn 2a, 11415 Estonia.
NCreator OÜ owns and operates www.naughtycreator.com along with its associated websites and mobile versions (referred to as the “Site,” "Platform," or using pronouns like we, us, our, etc.). Upholding your privacy is important to us, and we are dedicated to safeguarding it as outlined in this Privacy Policy (referred to as the “Policy”). This Policy defines the sorts of personal information that may be gathered from you as the User (referred to as you, your, yours, etc.), or that you might provide to us while using the services offered on the Site (referred to as the “Services”). Additionally, it details our procedures for the collection, utilization, storage, protection, and disclosure of your personal information.

Kindly review this Policy thoroughly to grasp our approach concerning your personal information and how we intend to handle it. If you disagree with this Policy, your only option is to discontinue using the Site. By entering or utilizing the Site, you acknowledge and consent to this Policy, agreeing to the collection, use, disclosure, storage, and safeguarding of your information as outlined herein.

We retain the right to modify, alter, or amend this Policy at any given time and in any manner we deem necessary. Your ongoing use of the Site following any amendments to this Policy will be considered as your acknowledgment and acceptance of these changes. Therefore, it's essential for you to regularly review this Policy and refer to the "Last Updated" date at the top of this page. Any updated or edited versions of this Policy will take precedence over previous versions immediately upon their publication.

Maintaining accurate and up-to-date personal information is crucial. Should any changes occur to your personal data while you engage with us, please ensure to notify us promptly. You can update or rectify any information through your account settings on our Site.

1. APPLICABILITY OF THIS POLICY (18+)

Our Services are strictly intended for individuals 18 years of age or above. Those under 18 years old are prohibited from using the Services. When using the Services, you affirm that you are at least 18 years old. Should we become aware of gathering information from or about an individual below the age of eighteen (18), we will promptly remove that data. If you suspect that we possess such information, kindly reach out to us at privacy@naughtycreator.com.

2. SOURCES OF PERSONAL DATA

We obtain your personal data from the following categories of sources:

  • Directly from you: This includes information provided during account creation, updates to your account, and interactions with us (e.g., User Data, Account Data).
  • Automatically or indirectly from you: Your use of our services generates data such as Transaction Data, Technical Data, and Usage Data.
  • From service providers: With lawful permission, we obtain Third-Party Onboarding Data and specific Technical Data from age and identity verification partners.

3. THIRD-PARTY LINKS

Our Site may contain links to third-party websites plug-ins, and applications. Clicking on those links or using those connections might result in third parties collecting or sharing your personal information.
Please note that we do not oversee or cover the privacy practices, security, or content of those external websites, plug-ins, or applications. It's advisable to review the privacy and cookie policies of those third parties to understand how they might use your personal data.

4. USAGE OF YOUR PERSONAL DATA

We may use your personal information for following purposes:

  • To grant you with access to the Site and use of the Services.
  • To enhance the Services and provide qualified customer support.
  • To identify you upon return to the Services.
  • To customize the Services based on your preferences.
  • To notify you about Service changes and our policies.
  • To observe and analyze traffic and usage trends related to the Services.
  • To ensure the security and integrity of the Services.
  • To use your personal information to fulfill our responsibilities and uphold our entitlements based on any agreements between you and us. This includes the terms outlined in this Policy and our Terms of Service.
  • To inspect and prevent any unauthorized or forbidden usage of the Services.
  • For marketing and advertising objectives.
  • For any other purpose with your consent.

5. SHARING YOUR PERSONAL DATA

We share personal data with the following categories of third parties:

  • Third-party service providers: These encompass various services like IT, payment processing, customer support, content moderation, text moderation, and age and identity verification/estimation. We share personal data with these parties based on the legal grounds that it's essential for our legitimate interests, particularly to receive necessary services that help our business operations.
  • Law enforcement, government bodies, and private individuals involved in legal proceedings. This includes situations where we respond to valid requests like lawful criminal investigations, civil lawsuits, administrative processes, subpoenas, court orders, or reasonable requests from authorities or individuals authorized to seek such information. We share personal data with these recipients based on specific reasons. These reasons include the need to follow the law, fulfill legal obligations, protect our or others' legitimate interests, and contribute to the public good. This sharing is particularly important when reporting illegal content, aiding authorities, regulators, and organizations, all aimed at safeguarding the safety of our users and others.
  • To potential buyers or those who may take over in case of a merger, partnership, transfer, sale of assets, or any similar business change, including situations like bankruptcy or dissolution. We do this because it's necessary for both our and the involved third parties' legitimate interests, particularly in evaluating and executing potential business transactions.
  • Our team of expert advisors, including legal consultants, financial experts, auditors, accountants, consultants, and insurance providers. These professionals will handle personal data only as required to offer their services to us. The reason we share personal data with these parties is because it's crucial for our business interests (specifically, receiving professional services).
  • Any other party with your consent.

6. CATEGORIES OF PERSONAL DATA

We collect or have third-party services collect various types of personal data about our users. This information is categorized in different groups for our handling and processing:

6.1 User Data:

  • Fans: E-mail address, phone number.
  • Creators: Full name, alias, residential address, country of residence, e-mail address, phone number, a copy of the government identity document, a "selfie" holding your government identity document, a social media account or personal website address (used for additional confirmation of your age and identity. This information also assists us in gaining insights into the type of content you may share on our platform), signature on release forms if you feature in another Creator's content.

6.2 Third-Party Onboarding Data:

  • Creators: A copy of the government identity document that you provide to our third-party providers, a “selfie” that you provide to our third-party providers, the results of the third-party age and identity verification process (pass/fail and reason for failing), metadata associated with the third-party age and identity verification process.

6.3 Face Recognition Data:

  • Creators: During onboarding, our third-party providers may use face recognition technology, so they can digitally confirm your identity. However, any data generated through this facial recognition process stays solely with our third-party provider. We, as a company, neither gather, obtain, hold, nor can access any of this facial recognition data at any point.

6.4 Account Data:

  • Fans: Profile name, password, avatars and headers of your Fan account, your subscriptions, comments on posts made from your Fan account, chat messages between you and other users, customer support queries that you submit to us.
  • Creators: Profile name, password, avatars and headers of your Creator account, your subscriptions, subscribers and referrals, posts that you have made to your Creator account, comments on posts made from your Creator account, chat messages between you and other users, customer support queries that you submit to us.

6.5 Financial Data:

  • Fans: Payment card details, billing address, funds added to your wallet.
  • Creators: Payment card details, billing address, funds added to your wallet, bank account information, pay-out country.

Please note: Any payments made to view the content of Creators are processed by our third-party payment providers. We do not obtain your complete payment card details, such as the card number, expiration date, or security code. Instead, the payment provider furnishes us with a secure "token" that represents your account, displaying your card's expiration date, type, and only the first six and last four digits of your card number.

6.6 Transaction Data:

  • Fans: Payments made from your Fan account to Creators, any failed payments.
  • Creators: Earnings, pay-out requests, payments made to your Creator account, payments made from your Creator account to other Creators, any failed payments.

6.7 Technical Data:

  • Fans and Creators: Internet or other electronic network activity information, including IP address, Internet Service Provider, device and type, name and version of browser.

6.8 Usage Data:

  • Fans and Creators: We use cookies for essential functions (enabling browsing and accessing specific website pages) and, upon your approval, for enhancing website performance (such as analyzing user interactions to improve the Services) and enabling certain website features (like remembering your logged-in status). Additionally, cookies help recognize your referral of other creators through a unique code if you're a Creator yourself. In some cases, data collected from cookies will be in a deidentified, aggregated or anonymized format. Presently, we don't employ cross-site tracking technologies, nor do we trade or share your personal data for cross-context behavioral advertising purposes.

7. IF YOU CHOOSE NOT TO SHARE YOUR PERSONAL DATA

In order to grant you access to the Services or their specific features as per our agreement outlined in the Terms of Service, we require specific personal data. Additionally, certain laws mandate us to process particular personal information. Kindly note that if you opt out of providing this information when requested, it might hinder our ability to grant you access to the Services or their specific features.

8. INTERNATIONAL USERS

This Policy applies to the gathering of personal information in the area where our operations are based. Different countries might demand more stringent privacy guidelines than the ones outlined here. If you're using our website from another country, you acknowledge and consent to the possibility of your personal information being moved to, held, and managed in the area where our operations are located or in the region specified by the third parties mentioned here. Additionally, you understand that the data protection and other legal regulations in our operational area or the specified third-party region might not offer the same level of coverage as those in your own country.

9. OPTIONS FOR MANAGING YOUR PERSONAL DATA

9.1 Managing your account information: If you have an account with us, you can update your account settings on our website. Keep in mind that changes to your settings may take some time to apply.

9.2 Control over device data access: You can manage the Services' access to your technical data through your device's "Settings" app. For example, you can revoke permission for the Services to access your network devices and location.

9.3 Opting out of certain email notifications: We do not currently send promotional emails. However, we do send account-related notifications (such as notifications for Creators about new subscribers, tips, or subscription renewals). You can choose to stop receiving specific types of emails from us by adjusting your notification preferences on our website. Alternatively, you can contact us via email privacy@naughtycreator.com with "E-mail notification opt-out" in the subject line. Please include your name and account email address in the body of the email.

Please be aware that certain essential automated email notifications necessary for providing the Services or mandated by applicable laws (e.g., account verification, transactional communications, service feature updates, technical and security notices) cannot be opted out of.

10. INFORMATION ABOUT YOUR PERSONAL DATA RIGHTS

You have specific entitlements regarding the gathering and handling of your personal information. You can assert these entitlements by reaching out to us at privacy@naughtycreator.com.

Under specific conditions and with some exceptions, you possess the right to:

  • Revoke your consent for us to process your personal data: Be aware that revoking your consent won't affect the legality of any processing done before your withdrawal.
  • Request access to or knowledge about your personal data: You can obtain a copy of the personal information we have about you and verify that we're lawfully managing it.
  • Ask for corrections to your personal data in our possession: You can rectify any incomplete or inaccurate personal information we hold about you.
  • Demand the deletion/removal of your personal data: You may request us to delete or remove personal information if there is no valid reason for us to keep processing it. This applies especially if you have objected to the processing (as mentioned below). Please note that we may not always comply due to specific legal obligations.
  • Ask for the limitation of handling your personal information: This means you can request us to pause the processing of your personal data, such as when you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of certain portions of your personal data to another party.
  • You also have the right to oppose the processing of your personal data if we are relying on our legitimate interest for processing, and there is something specific about your situation that prompts this objection.

We do not process personal data that is solely subjected to automated decision-making, especially when such decisions are likely to have a significant legal or similar impact on you.

11. EXERCISING YOUR RIGHTS

To enact your rights as outlined in Section 10 regarding your personal data, kindly reach out to us via privacy@naughtycreator.com. When submitting your request, please ensure it includes ample details for us to confirm your identity and effectively comprehend and address it.

In order to verify your identity, we might ask for more of your personal data, based on our connection and how sensitive your inquiry is. There are cases where we might not be able to fulfill a request for privacy rights, especially if we can not confirm your identity.

If your request is made through a third-party acting on your authorization, we'll need proof of their permission to submit the request on your behalf, like a signed document demonstrating their authority.

12. RETENTION OF PERSONAL DATA

Keeping in line with the law, we will retain your personal information for the duration necessary to serve the purposes outlined in this Policy. Yet, we may keep publicly available or de-identified data for legitimate business reasons without informing you or seeking your approval, as permitted by law.

13. SECURITY OF PERSONAL DATA

We prioritize data security and have taken steps to safeguard your personal information from unintentional loss and unauthorized access, usage, alteration, or disclosure. Your provided information is stored on our secure servers shielded by firewalls. However, transmitting personal data over the internet is not entirely risk-free. Despite our efforts to protect your data, we cannot assure the absolute security of information transmitted through our Platform. Any sharing of personal details is done at your own discretion and risk. We do not hold responsibility for any attempts to bypass privacy settings or security measures on the Platform.

14. SALES OF PERSONAL DATA

We do not engage in selling or distributing personal information to enable the display of targeted ads, which are chosen using personal data collected or deduced from an individual's interactions across various businesses, branded websites, apps, or services.

15. ASSISTANCE AND CONTACT INFORMATION

If you have any inquiries or feedback regarding this information, how NCreator OÜ gathers and utilizes your data as outlined in the Privacy Policy, your options, and privileges concerning this usage, or if you want to act upon your rights, feel free to reach out to us at privacy@naughtycreator.com.

We aim to answer any confirmed consumer request within thirty (30) days from when we receive it. In case we need more time, we will notify you in writing, explaining the reason and the additional time needed.

The information we share will cover only the twelve (12) months before the receipt of your request. Our response will also clarify any reasons why we might be unable to fulfill a request. When it comes to requests for data transfer, we will choose a format that allows you to easily use and transfer your personal information from one entity to another.

There is generally no charge for handling or responding to your confirmed consumer request, unless it is excessive, repetitive, or clearly baseless. If we decide a fee is necessary, we will explain why and provide you with an estimated cost before proceeding with your request.