Fanport Privacy Policy

6.1 Basic Account Information

6.2 Identity Verification Information

6.3 Payment Information

Complete credit card information is processed by the Company's payment processor. The Company only stores an alternative identifier called a "token".

6.4 Content Information

6.5 Usage Data

6.6 Technical Information

6.7 Communication Records

6.8 Inferred Information

The Company may analyze users' behavioral history, usage status, and other information to infer attribute information useful for service provision in order to provide and improve the Platform. This inferred information is used solely for the purpose of improving user experience and ensuring service safety.

7.1 Direct Provision from Users

Much of the personal information is provided directly by you:

• During account registration
• When setting up your profile
• When uploading content
• When registering payment information
• When contacting support

7.2 Automatic Collection

While using the Platform, the following information is automatically collected:

• Technical information sent from your browser or device
• Information collected through cookies or other tracking technologies
• Information about service usage

7.3 Acquisition from Third Parties

The Company may obtain information from the following:

• Identity verification service providers
• Payment processors
• Social media platforms (if you authorize account linking)
• Public sources (when necessary for legal compliance)

10.1 Age and Identity Verification Process

• The Company uses third-party service providers to conduct age and identity verification.
• In this process, the third-party provider collects:
  • Government-issued ID images
  • A short .gif created from selfie images
• The third-party provider uses facial recognition technology to compare the two images and verify age and identity.

10.2 Handling of Facial Recognition Data

Important Safeguards:

• Facial recognition data is collected and processed only by the third-party provider
• The Company does not collect, receive, possess, or access facial recognition data
• The Company only receives the verification result (approved/rejected and reason)

10.3 Reasons for Using Facial Recognition Technology

• To prevent fraudulent facial image spoofing
• To prevent uploading of forged identification documents
• To ensure the safety and security of the Platform
• To comply with applicable laws and regulations

10.4 Periodic Identity Verification

• During the account retention period, the Company may periodically request identity verification.
• Where permitted by law, the third-party provider may retain facial recognition data and use it during re-verification.
• In this case, you will not need to resubmit identification documents during re-verification.

10.5 Withdrawal of Consent

You may withdraw your consent to the retention of facial recognition data at any time. To withdraw, please contact privacy@fanport.com (temporary). However, if you withdraw consent, you will need to resubmit identification documents during re-verification.

11.1 Service Provision

• Account creation and management
• Matching creators and viewers
• Content distribution
• Subscription plan management
• Providing messaging functionality
• Providing customer support
• Service personalization

11.2 Identity and Age Verification

• Confirming users are 18 years of age or older
• Verifying user identity
• Preventing impersonation
• Preventing fraudulent account use

11.3 Payment Processing

• Processing payments from viewers to creators
• Paying compensation to creators
• Recording transaction history
• Detecting and preventing fraudulent transactions
• Processing refunds

11.4 Safety Assurance

• Monitoring Terms of Service violations
• Detecting and removing prohibited content
• Detecting spam, fraud, and malware
• Preventing hacking and unauthorized access
• Responding to security incidents

11.5 Responding to Terms Violations

• Content moderation
• Investigating Terms of Service violations
• Responding to disputes between users
• Responding to intellectual property infringement
• Determining account suspension or deletion

11.6 Legal Compliance

• Fulfilling legal obligations
• Cooperating with law enforcement agencies
• Responding to court orders
• Fulfilling tax reporting obligations
• Anti-money laundering
• Complying with child protection laws

11.7 Service Improvement

• Improving service quality
• Developing new features
• Bug fixes
• Optimizing user experience
• Creating and analyzing statistical data

11.8 Technology Development and Improvement

The Company uses personal information for the following purposes:

• Improving service quality
• Optimizing user experience
• Providing content recommendations
• Developing and improving automation technologies

These processes enable us to provide more personalized experiences. The Company uses anonymized or pseudonymized data whenever possible to protect privacy.

12.1 Performance of Contract

To perform contracts based on the Terms of Service (e.g., service provision, payment processing, account management)

12.2 Compliance with Legal Obligations

When required by law (e.g., tax reporting, identity verification, reporting illegal content)

12.3 Legitimate Interests

When necessary for the legitimate interests of the Company or third parties (e.g., preventing fraud, ensuring security, improving services)

12.4 Consent

When explicit consent has been obtained for specific processing (e.g., use of facial recognition technology). Consent may be withdrawn at any time, but this does not affect the lawfulness of processing conducted before withdrawal.

13.1 Service Providers

We share necessary information with the following service providers:

• Payment processors - for payment processing
• Identity verification service providers - for age and identity verification
• Content moderation services - for ensuring content safety
• Cloud storage providers - for secure data storage
• Customer support tool providers - for providing support
• Analytics tool providers - for service analysis

These providers process personal information only in accordance with our instructions.

13.2 Professional Advisors

We share necessary information with the following professionals:

• Legal counsel
• Accountants
• Auditors
• Consultants
• Insurance companies

13.3 Business-Related

We share information with related third parties in the following cases:

• Business sale, merger, or acquisition
• Corporate reorganization
• Group reorganization

13.4 Law Enforcement and Regulatory Authorities

We share information with authorities in the following cases:

• When disclosure is required by law
• In response to court orders
• When necessary for crime prevention, investigation, or prosecution
• When necessary for national security

• To prevent imminent danger to life, body, or property
• To protect the safety of children
• To prevent serious crimes
• To prevent suicide or self-harm

17.1 Technical Measures

• Data encryption (at rest and in transit)
• Implementation of firewalls and intrusion detection systems
• Access control and user authentication
• Regular security audits
• Vulnerability scanning and penetration testing

17.2 Organizational Measures

• Security training for employees
• Restriction of access rights to personal information
• Conclusion of confidentiality agreements
• Development of incident response plans
• Regular security reviews

17.3 Important Notes

Because there are inherent risks in transmitting information over the Internet and electronic storage, the Company cannot guarantee the complete security of personal information. You should also take the following measures:

• Do not share passwords with others
• Change passwords regularly
• Log out on public computers

18.1 During Service Provision Period

While the account is active or for the period necessary to provide services

18.2 Legal Retention Obligations

For the period required by law (e.g., tax-related information for up to 7 years)

18.3 Records of Terms Violations

Records related to Terms of Service violations for the period necessary for investigation, law enforcement cooperation, and litigation response

18.4 Legal Disputes

For the period necessary to exercise or defend legal claims

18.5 Timing of Deletion

Personal information will be deleted in the following cases:

• When the account is deleted (after a certain period)
• When the retention period expires
• When a user requests deletion (except when retention is required by legal obligation)
• When the collection purpose is achieved and there is no longer a need for retention

19.1 What Are Cookies

Cookies are small text files that websites store in your browser. Cookies allow websites to recognize your device and remember certain information.

19.2 Types of Cookies Used

19.3 Other Tracking Technologies

In addition to cookies, the following technologies may be used:

• Web beacons
• Pixel tags
• Local storage
• Session storage

19.4 Cookie Management

You can disable cookies through your browser settings. However, if you disable cookies, some features of the Platform may not function properly.

Cookie settings for major browsers:

• Chrome: Settings → Privacy and security → Cookies
• Safari: Preferences → Privacy
• Firefox: Options → Privacy and Security
• Edge: Settings → Cookies and site permissions

19.5 Important Policy

• The Company does not use cross-site tracking technologies
• We do not sell or share personal information with third parties for advertising purposes

20.1 Right of Access (Disclosure Request)

The right to request disclosure of your personal information held by the Company

Information to be disclosed:

• Types of personal information collected
• Purpose of collection
• Third parties with whom information is shared
• Retention period
• Copy of personal information

20.2 Right to Rectification

The right to request correction if your personal information is inaccurate or incomplete

20.3 Right to Erasure (Right to be Forgotten)

20.4 Right to Restriction of Processing

The right to request restriction of processing of personal information in the following cases:

• When disputing the accuracy of personal information
• When processing is unlawful but you prefer restriction instead of deletion
• When the Company no longer needs the personal information but you need it for legal claims

20.5 Right to Data Portability

The right to receive personal information meeting the following conditions in a structured, commonly used, machine-readable format, and to transfer to another controller:

• Processed based on consent or contract
• Processed by automated means

20.6 Right to Object

The right to object to processing based on legitimate interests or public interest, for reasons related to your particular situation

20.7 Withdrawal of Consent

The right to withdraw consent at any time for processing based on consent. However, this does not affect the lawfulness of processing conducted before consent withdrawal.

21.1 Request Methods

To exercise the above rights, the following methods are available:

• Make changes directly from account settings within the Platform
• Email contact to privacy@fanport.com (temporary)
• Submit through the inquiry form within the Platform

21.2 Identity Verification

To protect your personal information, we will verify your identity before responding to requests. We may ask you to provide additional information for identity verification.

21.3 Requests by Third Parties

When a third party makes a request on your behalf, documents proving that the third party has been granted proper authority (power of attorney, etc.) are required.

21.4 Response Period

The Company will respond within 30 days in principle from receiving the request. Depending on the complexity or number of requests, we may extend this by an additional 30 days. If extended, we will notify you.

22.1 Changing Personal Information

You can update personal information at any time from account settings. Changes may take time to be reflected.

22.2 Managing Access to Device Information

You can control the Platform's access to technical information from your device's "Settings" app.

22.3 Email Notification Opt-Out

You can turn off certain types of email notifications from the notification settings on the Platform. However, the following notifications cannot be turned off:

• Account confirmation
• Transaction-related notifications
• Feature changes and updates
• Technical and security notifications

24.1 For EU/EEA Residents (GDPR)

• Applicable Law:For residents of the European Union and European Economic Area, the GDPR (General Data Protection Regulation) applies.
• Legal Basis:The Company processes personal information based on the legal grounds specified in Article 12.
• EU Representative:The Company has appointed an EU representative under GDPR Article 27. For details, please contact us at the contact information in Article 28.
• Data Transfers:Transfer of personal information outside the EEA is conducted with appropriate safeguards such as Standard Contractual Clauses.

24.2 For California Residents (CCPA/CPRA)

• Applicable Law:For California residents, the CCPA (California Consumer Privacy Act) and CPRA (California Privacy Rights Act) apply.
• Categories of Personal Information Collected:As specified in Article 6. These fall under the following categories of California law:
  • Identifiers
  • Customer records
  • Protected classification characteristics
  • Commercial information
  • Biometric information (facial recognition data - processed only by third-party providers)
  • Internet/network information
  • Sensory information
  • Professional/employment information
  • Other personal information
  • Inferences
• Sale and Sharing of Personal Information:
  • The Company does not sell personal information to third parties in exchange for money
  • We do not share personal information for cross-context behavioral advertising purposes
• California Resident Rights:
  • Right to know (right to know about personal information collected, used, and shared)
  • Right to deletion
  • Right to correction
  • Right to opt-out (where applicable)
  • Right to limit use of sensitive information
  • Right to non-discrimination
• Sensitive Information:The following constitute sensitive information:
  • Government-issued identification numbers
  • Payment information
  • Facial recognition data (processed only by third-party providers)

  These are used for service provision, ensuring security, and legal compliance.

• Retention Period:As specified in Article 18
• Automation Technology:The Company uses automation technology for service provision and improvement.

24.3 Other U.S. State Laws

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and other states that have enacted comprehensive privacy laws also have specific privacy rights. Residents of these states have similar rights to California residents. For how to exercise your rights, please see Article 21.

Appeals:

If you are dissatisfied with the Company's decision, you may appeal through the contact information in Article 28. If your appeal is rejected, you may contact your state's attorney general.

24.4 Japan Personal Information Protection Act

• Applicable Law:For residents of Japan, the Personal Information Protection Act applies.
• Personal Information Handling Business Operator:The Company is a personal information handling business operator under the Personal Information Protection Act.
• Purposes of Use:As specified in Article 11
• Provision to Third Parties:As specified in Articles 13 and 14
• Provision of Personal Relational Information:The Company may provide users' behavioral history, usage status, and other information to third parties who are expected to obtain such information as personal information for the purpose of providing or improving services. This may constitute the provision of personal relational information to third parties as stipulated in Article 31 of the Personal Information Protection Act, and the Company will conduct necessary confirmations and record-keeping in accordance with laws and regulations.
• Requests for Disclosure, Correction, Suspension of Use, etc.:Please contact us using the methods specified in Article 21.
• Complaints:Personal Information Protection Commission
  • Address: 3-2-1 Kasumigaseki, Chiyoda-ku, Tokyo 100-8970
  • Phone: 03-6457-9680 (main)

28.1 General Inquiries

For questions, comments, or complaints about this Policy or the handling of personal information, please contact us by the following methods:

• Email: privacy@fanport.co (temporary)
• Inquiry Form: Inquiry form within the Platform

28.2 Data Protection Officer

The Company has appointed a person responsible for personal information protection. For professional questions about data protection, please contact the Data Protection Officer through the above contact information.

28.3 Appeal to Supervisory Authorities

If you have complaints about the handling of personal information, you have the right to lodge a complaint with the relevant supervisory authority:

• Japan: Personal Information Protection Commission
• EU/EEA: Data protection authority in your country of residence
• USA: State Attorney General's Office (varies by state)