Privacy Policy

Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using the table of contents above to find the section you are looking for.

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
• Do we process any sensitive personal information? Some information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
• Do we collect information from third parties? We may collect information from third parties such as referral information, identity verification and fraud prevention services, and advertising or analytics platforms.
• How do we process your information? To provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law — only when we have a valid legal reason to do so.
• How do we keep your information safe? We have adequate organisational and technical processes in place, though no electronic transmission or storage can be guaranteed 100% secure.
• What are your rights? Depending on where you are located, applicable privacy law may mean you have certain rights regarding your personal information.
• How do you exercise your rights? The easiest way is by submitting a data subject access request, or by contacting us at support@ifanzy.com.

1.What information do we collect?

We collect and process the following categories of personal data depending on how you use the Platform:

Data you provide directly

• Identity data (e.g. name, date of birth, nationality)
• Contact data (e.g. email address, phone number)
• Payment data (e.g. card or bank details, billing address)
• Creator verification documents (e.g. ID, liveness scans)
• Communications (e.g. support messages, complaints)

Data we collect automatically

• Usage data (e.g. login times, clicks, viewed Content, messages)
• Technical data (e.g. IP address, browser type, device model)
• Location data (based on IP or device permissions)
• Session activity (e.g. navigation, interactions)

Data from third parties

• Referral information
• Identity verification and fraud prevention services
• Advertising or analytics platforms

We may combine this data to improve our services, protect users, and detect misuse.

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we may also process sensitive personal information such as biometric data for verification purposes.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases. All payment data is handled and stored by secure payment processors like Stripe. You may find their privacy notice here: https://stripe.com/privacy.

Children's Privacy

Our Services are not intended for use by children under the age of 18 ("Children"). We do not knowingly collect personal data from Children. If you are under 18, you must not use our Services or provide any personal data to us. If you become aware that a Child has provided us with personal data without parental consent, please contact us immediately at support@ifanzy.com. If we learn that we have collected personal data from a Child without verification of parental consent, we will take steps to delete that information from our servers.

Age Verification Data

To comply with global age verification laws, we process additional data for users in regulated jurisdictions. This includes government ID details, biometric matching data, and verification documents for creator verification purposes. Age verification is performed by approved third-party providers under strict data processing agreements. We store only the minimum data necessary for compliance, such as verification status (pass/fail) and timestamp. For Creative Users, we may retain document data as required by applicable laws (e.g., USC 2257 requirements). Age verification data is processed based on legal obligation and legitimate interest, retained for the duration required by law or your account status, subject to enhanced security measures, and never used for marketing purposes.

2.How do we process your information?

We process your personal data for the following purposes:

3.What legal bases do we rely on to process your information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when necessary to fulfil our contractual obligations to you.
• Legal Obligations. We may process your information where necessary for compliance with our legal obligations.
• Vital Interests. We may process your information where necessary to protect your vital interests or the vital interests of a third party.
• Legitimate Interests. We may process your information when necessary to achieve our legitimate business interests, provided that your interests and fundamental rights do not override those interests.

4.When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

We only share your personal data where necessary and for legitimate purposes. This includes sharing with:

• Payment processors
• KYC and fraud tools
• Analytics providers
• Marketing platforms (only with your consent)
• Customer support tools
• Legal authorities, where required by law or court order

Wherever possible, we enter into data processing agreements with these providers to ensure your data is handled securely. The categories of third parties we may share personal information with are as follows:

• Payment Processors
• Data Analytics Services
• Cloud Computing Services
• Data Storage Service Providers
• User Account Registration & Authentication Services
• Government Entities (where required by law)

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates. We may share your information with our affiliates.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

Our Services may contain links to external websites or services not operated by us. We are not responsible for the content, privacy practices, or data use policies of those third parties. We recommend reviewing their privacy notices before submitting any data.

5.Do we use cookies and other tracking technologies?

In Short: We currently do not use cookies or similar tracking technologies to collect or store your information.

While we reserve the right to use such technologies in the future to enhance user experience, improve platform performance, or provide additional functionality, we are not currently utilizing any cookies, web beacons, or other automated data collection methods. Should this change in the future, we will update this Privacy Notice accordingly and provide clear information about the types of technologies used and how you can manage your preferences.

6.Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Singapore. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information, including facilities in the United States, Japan, and other countries.

Where personal data is transferred internationally, we ensure appropriate safeguards are in place, such as:

• Adequacy decisions by the relevant authorities
• Standard Contractual Clauses (SCCs)
• UK Addendum to SCCs (if required)

7.How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We retain your personal data only for as long as necessary for the purposes outlined in this Policy, including:

• While you maintain an active Account
• For legal, regulatory, tax, or audit purposes
• For a limited period after account closure, as required by law

After this period, your data is securely deleted or anonymised.

8.How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We take the protection of your personal data seriously. We implement appropriate technical and organisational measures to prevent accidental loss, unauthorised access, or misuse of personal data. These include:

• Secure servers and encryption of sensitive data;
• Access restrictions and confidentiality agreements for staff;
• Breach detection and notification procedures, in line with legal obligations.

You are responsible for keeping your account credentials confidential and must not share them with others.

9.What are your privacy rights?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

You have the following rights under applicable data protection law:

• Right to access — Request a copy of your personal data
• Right to rectification — Correct inaccurate or incomplete data
• Right to erasure — Ask us to delete your data under certain conditions
• Right to restrict processing — Limit how we use your data
• Right to data portability — Receive your data in a structured format
• Right to object — Stop certain types of processing
• Right to withdraw consent — Where processing is based on consent
• Right to lodge a complaint — With your local data protection authority

To exercise your rights, contact support@ifanzy.com.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

10.How can you contact us about this notice?

If you have questions or comments about this notice, you may contact us by post at:

11.How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please submit a request to support@ifanzy.com.

12.Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice.