1. Information We Collect
A. Identity Verification Data
- Government-Issued ID: Name, date of birth, ID number, and photo.
- Facial Image: A live or uploaded photo for verification.
- Metadata: Timestamp of verification and device/IP address used.
B. Account Information
- Username: Chosen by you to associate with your verified status and identify the accounts you use to interact with creators or fans.
- Creator/User Linkage: Data linking creators to users they verify.
2. How We Use Your Information
- Verification: Confirm your identity to creators.
- Security: Prevent fraud, impersonation, and misuse of our service.
- Legal Compliance: Respond to valid legal requests (e.g., subpoenas).
- Improvements: Analyze anonymized data to enhance our service (no personal data is used for marketing).
3. Legal Basis for Processing
- Consent: By submitting your data for verification, you consent to its use for identity confirmation.
- Legal Obligation: Disclosures to law enforcement under valid legal requests.
- Legitimate Interest: Protecting creators and users from fraud/harm.
4. How We Share Your Information
- Law Enforcement: Only in response to valid legal requests (e.g., subpoenas, court orders) for criminal investigations (e.g., cyberstalking, threats).
- Third-Party Vendors: Trusted partners (e.g., cloud storage providers) who assist in data processing under strict confidentiality agreements.
- Never Shared with Creators: Identity information (e.g., government ID) is not disclosed to creators unless legally compelled.
5. Data Security
- Encryption: All data is encrypted at rest (AES-256) and in transit (TLS 1.3).
- Access Controls: Strict internal protocols limit access to authorized personnel only.
- Audits: Regular penetration testing and security audits.
6. Data Retention
- Retention Period: 5 years from last verification, unless:
- You request deletion (see Section 7).
- Required for legal investigations.
- Deletion: Data is permanently erased from all systems upon expiration or valid deletion request.
7. Your Rights
Depending on your jurisdiction (e.g., GDPR, CCPA), you may:
- Access: Request a copy of your data.
- Correct: Update inaccurate information.
- Delete: Request erasure of your data (unless retained for legal reasons).
- Opt-Out: Withdraw consent for future data processing (note: this will revoke your verification status).
To exercise these rights, contact Privacy@Fmlyr.com
8. International Data Transfers
- Data Storage: Stored in the USA with safeguards for cross-border transfers (e.g., GDPR Standard Contractual Clauses).
- Compliance: Adherence to local laws (e.g., PIPL for China).
9. Updates to This Policy
We will notify users of material changes via email or in-app alerts. Continued use constitutes acceptance.
Last Updated: [2/22/2025]