Privacy Policy

FFanoxie Ltd (“Fanoxie”, “we”, “us”, “our”) respects your privacy and is committed to protecting the Personal Data we process about you. Fanoxie operates a social network and content-sharing platform that enables: (i) Creators to share and monetise their own content (and subscribe to other Creators); and (ii) Fans to subscribe to and view Creator content (the “Services”).

This Privacy Policy (“Policy”) explains our practices regarding Personal Data processed about Creators, Fans, Content Collaborators (individuals who feature in content uploaded by a Creator), and individuals whose Personal Data we process in business relationships. We act as a data controller for Personal Data processed in connection with the Services.

1) What is Personal Data?

“Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. We may also create or receive deidentified, aggregated, or anonymised information that cannot reasonably be used to identify you. Such information is not Personal Data, and our use of it is not subject to this Policy.

2) Keeping your information up to date

It is important that the Personal Data we hold is accurate and current. Please update your account details in your Fanoxie settings if your information changes.

3) Applicability and 18+ requirement

This Policy supplements, and forms part of, our Terms of Service (including our Acceptable Use Policy). The Services are strictly intended for individuals 18 years of age or older. By using the Services, you confirm that you are 18 years or older.

4) Third-party links

The Services may include links to third-party websites, plug-ins, or applications. Clicking those links may allow third parties to collect or share your Personal Data. We are not responsible for those third parties’ privacy practices. Review their privacy and cookie notices before providing Personal Data.

5) If you choose not to provide Personal Data

Certain Personal Data is required to provide the Services and to comply with law. If you choose not to provide requested information, we may be unable to provide the Services or specific features.

6) Updates to this Policy

We may update this Policy from time to time. Updates are effective upon posting on the Services. If changes are material, we will use reasonable efforts to notify you (e.g., via in-product notice or account message).

7) Categories of Personal Data we process

We, or third-party providers acting on our behalf, process the following categories of Personal Data. Items marked * may also be requested from Content Collaborators where a release form is required.

A. User Data

B. Third-Party Onboarding Data (collected directly by verification providers)

C. Account Data

D. Financial & Tax Data

* Fanoxie does not receive full card numbers or security codes. Payments are handled by third-party payment processors who provide tokenised references and limited card metadata.

E. Transaction Data

Earnings; payout requests; payments to/from accounts; failed payments; chargeback metadata.

F. Technical Data

IP address and country code; user agent; device/OS details; logs and security telemetry.

G. Usage Data & Cookies

Pages viewed; features used; session duration; referral URLs; cookie identifiers and consent preferences. See our Cookie Policy for details.

H. Content Data

Photos, videos, audio, and text uploaded to the Services, plus associated metadata produced by normal platform operation.

I. Safety & Moderation Data

Reports and flags; automated/human moderation outcomes; records of restricted or banned accounts.

8) Onboarding processes

Creators

Before a Creator account is enabled, we will:

• Collect Creator User Data and relevant Financial/Tax Data
• Check country of residence for lawful access
• Conduct third-party age and identity verification
• Screen for prior bans and risk indicators
• Capture business/tax details where applicable for payouts and compliance

Content Collaborators

Individuals appearing in a Creator’s content may be required to:

• Complete third-party age and identity verification
• Provide a signed release form
• Provide specified User Data as above

Fans

Before a Fan account is enabled, we will:

• Collect Fan User Data and payment details (if subscribing)
• Check country of residence for lawful access
• In certain locations or scenarios, require age estimation or third-party age/ID verification

Third-party verification / age estimation

• Performed by vetted providers using your selfie and/or government ID
• Providers may use face recognition to match images or estimate age
• Fanoxie does not access biometric templates; we receive result status (pass/fail, reason) and limited metadata required for record-keeping and safety
• Where permitted by law, providers may retain data to streamline re-authentication; you may request withdrawal of such retention (which may require a full re-verification later)

9) How and why we use Personal Data (lawful bases)

We process Personal Data for, or based on, one or more of the following legal bases: consent, performance of a contract, legitimate interests, compliance with legal obligations, and where applicable public interest.

We will only use Personal Data for the purposes for which it was collected unless another purpose is compatible.

10) How we obtain Personal Data

• Directly from you: account registration, profile updates, messaging, content uploads, support requests.
• Automatically: through your use of the Services (Technical and Usage Data).
• From service providers: verification outcomes, payment tokens/metadata, analytics, security/fraud signals.
• From integrations you authorise: e.g., social logins or linked accounts (where supported).

11) Sharing Personal Data

We do not sell Personal Data. We may share Personal Data with:

• Service providers/processors: IT hosting and storage, security, age/ID verification or age estimation, payment processing, tax automation, analytics, communications, moderation
• Professional advisers: legal counsel, auditors, accountants, bankers, insurers
• Corporate transaction parties: prospective or actual buyers, investors or affiliates in connection with a sale, merger, or reorganisation
• Group companies: for centralised operations consistent with this Policy
• Authorities and organisations: governmental/regulatory bodies (including law enforcement and tax authorities) and relevant non-government organisations where required or in the public interest (e.g., reporting illegal content)
• Other users: limited profile information necessary to operate the Services (e.g., Creators may see a Fan’s username and subscription status)

Recipients process Personal Data only for the purposes described in this Policy and subject to appropriate safeguards.

12) International data transfers

We are UK-based and operate globally. Where we transfer Personal Data outside the UK/EEA/Switzerland, we rely on:

• Adequacy regulations/decisions, or
• Standard Contractual Clauses with supplementary measures, or
• Other lawful transfer mechanisms.

Contact us if you would like more information about applicable safeguards.

13) Retention

We retain Personal Data for as long as reasonably necessary for the purposes set out in this Policy, including:

• Service delivery: for the life of your account and as needed to provide features
• Trust & safety: for as long as necessary to investigate incidents, assist lawful requests, and enforce restrictions
• Legal and compliance: statutory retention periods (e.g., many tax/accounting records up to 7 years) or preservation orders
• Litigation: for limitation periods and as required to establish, exercise, or defend claims

We delete or anonymise data sooner where required by law or where retention is no longer necessary.

14) Your rights

Subject to local law and certain exemptions, you may have the right to:

• Access your Personal Data and obtain a copy
• Correct inaccurate or incomplete information
• Delete/erase your Personal Data
• Restrict or object to certain processing
• Port certain data to another controller
• Withdraw consent where processing is based on consent (without affecting prior lawful processing)
• Lodge a complaint with a supervisory authority (see Section 19)

We do not engage in solely automated decision-making that produces legal or similarly significant effects.

15) Exercising your rights

Submit requests through your account or email privacy@fanoxie.com. We may ask for information to verify your identity and our relationship with you. If a request is made by an authorised agent, we require proof of authority (e.g., signed authorisation or valid power of attorney).

16) Your choices and controls

• Account settings: update or delete information and manage preferences
• Device permissions: manage device-level permissions (e.g., notifications)
• Email preferences: manage categories in settings or via unsubscribe controls; you cannot opt out of strictly necessary service emails
• Cookies: manage preferences via our consent banner and your browser; see our Cookie Policy

17) Security

We implement appropriate technical and organisational measures designed to protect Personal Data, including encryption in transit, access controls, logging/monitoring, and periodic security reviews. No system is perfectly secure and we cannot guarantee absolute security.

18) Minors

The Services are 18+ only. We do not knowingly collect Personal Data from anyone under 18. If you believe a minor has provided data, contact us and we will take appropriate action.

19) Additional U.S. state privacy disclosures

• No “sales” or “sharing” for targeted advertising: we do not sell Personal Data and do not share Personal Data for cross-context behavioural advertising.
• Sensitive information: some elements processed by us or our providers may be deemed “sensitive” under state law (e.g., government identifiers, partial payment card data, verification data). We use such data only as necessary to operate the Services, perform a contract, comply with law, ensure safety, or as otherwise permitted.
• Deidentified information: where we maintain deidentified information, we keep it deidentified and will not attempt to reidentify except as permitted by law.
• Appeals: if your request is denied, you may appeal by contacting us (Section 21). If denied again, you may contact your state Attorney General.
• California-specific summary: categories collected include Identifiers; Customer Records; Protected Classifications (age); Commercial Information; Internet/Network Information; Content you upload; Professional/Employment information (business contacts); Inferences from usage; and biometric-related verification data handled by third-party providers. Sources, purposes, and disclosures are described in Sections 7–12 and 9. We may offer referral or promotional programs; associated Personal Data is processed per this Policy and you can opt out at any time.
• Nevada: we do not sell Personal Data; Nevada residents may still send a sale opt-out request to our contact below.

20) Assistance and contact information

We have appointed a Data Protection Officer (DPO) to handle questions, requests, and concerns about this Policy and our data practices.

Supervisory authority: You may lodge a complaint with the UK Information Commissioner’s Office (ICO) or your local data protection authority.

EU/Swiss representative: If and when FFanoxie Ltd appoints an EU or Swiss representative, we will update this section with contact details.

21) Law enforcement and regulatory requests

We will respond to lawful requests consistent with applicable law and our obligations to user safety and privacy. We may preserve or disclose information if required by law, regulation, subpoena, court order, or to protect individuals, our users, or our Services.

22) Glossary (summary)

• Controller: entity that determines purposes and means of processing Personal Data.
• Processor: entity that processes Personal Data on behalf of a controller.
• Legitimate interests: our interest in operating, securing, and improving the Services, balanced against your rights.
• Biometric information: data derived from biological characteristics (e.g., face templates). FFanoxie Ltd does not collect or store biometric templates; third-party verification providers may process such data to verify age/identity and return results to us.