FansClique Privacy Policy

Effective Date: 1 September 2024

FansClique, is owned and operated by Mediagaze Limited. ("we," "our," or "us"), is
committed to protecting your privacy and ensuring the safety of your personal
information. This Privacy Policy outlines how we collect, use, share, and protect your
data, in compliance with the Nigeria Data Protection Regulation (NDPR), the General Data
Protection Regulation (GDPR), and other applicable global data protection laws.

FansClique is committed to safeguarding your personal data and ensuring that it is used in a
secure, lawful, and transparent manner. This Privacy Policy explains how we collect, use, and
protect your data in compliance with international data protection laws, including the General
Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Protection of
Personal Information Act (POPIA), Nigerian Data Protection Regulation (NDPR), and various
African data protection regulations. By using FansClique, you agree to the terms of this Privacy
Policy.

1. Introduction
At FansClique, we value your privacy. This Privacy Policy outlines how we collect and process
your personal data, your rights regarding that data, and the measures we take to ensure your
data remains secure. This policy applies to all users, including visitors, creators, and fans,
regardless of location.

2. Data Collection
2.1 Types of Data Collected
We collect the following personal data to enhance your experience on FansClique:
- Personal Information: Name, email, date of birth, phone number, and username.
- Financial Data: Payment details such as bank account information or credit card numbers.
- Content Data: Media files (photos, videos) shared by creators.
- Usage Data: IP address, device type, browser information, and platform interactions.
- Communication Data: Messages between users and customer support interactions.
- Cookie Data: Information collected via cookies to personalize your experience.

2.2 Data Collection Methods
We collect data when you:
- Sign up for an account on FansClique.
- Subscribe, send tips, or engage with Pay-Per-View (PPV) content.
- Participate in the YouTube-style short video discovery page.
- Interact with our support team.
More information on our data collection practices can be found in our [Data Policy] see more
details below section 12.

3. How We Use Your Data
3.1 Purposes for Using Data
We use your data to:
- Provide and improve the FansClique platform.
- Process payments between creators and fans.
- Verify user identities and enforce age verification policies.
- Personalize the platform experience for users.
- Provide customer support and respond to inquiries.
- Detect and prevent fraudulent activities on the platform.
For more on how we use data, refer to our Terms of Use And Data Policy

3.2 Legal Basis for Processing
We process personal data based on:
- Consent: Provided when you create an account.
- Contractual Obligations: To fulfill services outlined in our Terms of Use.
- Legitimate Interests: Improving platform functionality and security.
- Legal Compliance: Adhering to applicable regulations.

4. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to enhance your user experience by:
- Remembering your preferences.
- Tailoring recommendations based on your activity.
- Monitoring the performance of the platform.
You can control your cookie preferences through browser settings. Disabling cookies may affect
your experience.
Visit our Cookie Policy for more details.

5. Data Sharing
5.1 Sharing with Third Parties
FansClique does not sell your data. However, we may share it with:
- Service Providers: Including payment processors and data storage providers.
- Legal Authorities: When required by law.
- Business Transactions: In the event of mergers or acquisitions.
We ensure that third-party partners are compliant with data protection agreements to maintain
the confidentiality of your data.

6. Data Security
We implement robust security measures to protect your personal data, including:
- Encryption: Protecting your data during transmission and storage.
- Access Controls: Restricting access to personal data.
- Security Audits: Regular reviews of our systems to maintain security.
- Fraud Detection: Systems to monitor for suspicious activity.
In case of a data breach, we will notify affected users and relevant authorities as required.

7. Your Rights
You have rights over your personal data under various global data protection laws.

7.1 GDPR (European Users)
European users have the right to:
- Access, correct, or delete personal data.
- Restrict processing or object to marketing.
- Withdraw consent for data use at any time.
For more information, refer to our GDPR Policy

7.2 CCPA (California Users)
California users have the right to:
- Know what personal data is collected.
- Request deletion of personal data.
- Opt out of data sales (FansClique does not sell personal data).
- Not face discrimination for exercising privacy rights.
Learn more in our CCPA Policy

7.3 POPIA (South African Users)
Under POPIA, South African users can:

- Access their data and request corrections.
- Object to marketing or certain data processing activities.
- Withdraw consent for data processing.
More information can be found in our POPIA Policy

7.4 NDPR (Nigerian Users)
Nigerian users have the right to:
- Access and correct personal data.
- Request data deletion.
- Object to certain types of data processing.
- Withdraw consent for data processing at any time.
For more, refer to our NDPR Policy

7.5 Other African Data Protection Laws
FansClique complies with data protection laws across various African countries, including:
- Kenya Data Protection Act (DPA)
- Ghana Data Protection Act (Act 843)
- Mauritius Data Protection Act
- Tunisian Law on Personal Data Protection
- Morocco Law No. 09-08
- Egypt Personal Data Protection Law (PDPL)
For more information on specific African laws, see our detailed Cross-African Data Protection
Policy*

8. Data Retention
We retain your data for as long as necessary to provide services or comply with legal
obligations:
- Account Data: Retained until account deactivation.
- Transaction Data: Kept for seven years for auditing purposes.
- Communication Data: Retained for a year to resolve disputes.
You may request the deletion of your data by contacting us at [email protected]

9. Cross-Border Data Transfers
FansClique operates globally, and your data may be transferred to servers outside your home
country. We ensure that appropriate safeguards, such as Standard Contractual Clauses
(SCCs), are in place for data transfers in compliance with data protection laws.
By using FansClique, you agree to cross-border data transfers where necessary.

10. Children’s Privacy
FansClique is not intended for individuals under 18. We do not knowingly collect data from
minors. If we become aware of such collection, we will delete the data immediately.
Please contact us if you suspect that we have collected data from someone under 18 years.

11. Cross-African Data Protection Compliance
FansClique complies with data protection regulations across various African countries, ensuring
that your personal data is handled lawfully and securely in compliance with:
- Nigerian Data Protection Regulation (NDPR)
- Protection of Personal Information Act (POPIA) of South Africa.
- Kenya Data Protection Act (DPA)
- Ghana Data Protection Act (Act 843)
- Mauritius Data Protection Act.
- Tunisian Law on the Protection of Personal Data.
- Moroccan Law No. 09-08lll
- Egyptian Personal Data Protection Law (PDPL)
Our commitment to cross-African data protection means your data is treated with the highest
level of security and compliance.

12 DATA POLICY
FansClique Data Policy
At FansClique, we are committed to ensuring that personal data is handled with the
highest standards of privacy, security, and compliance. This Data Policy outlines how we
collect, process, and protect your personal information in alignment with global and local data
protection laws, including GDPR (Europe), CCPA (California), POPIA (South Africa), NDPR
(Nigeria), and various other applicable regulations in jurisdictions where FansClique operates.
By using FansClique, you consent to the collection and use of your data as described in this
Data Policy. This policy applies to all users, including both creators and fans.

1. Data Collection and Categories
We collect personal data for various reasons, primarily to provide services and improve your
experience on the FansClique platform.

1.1 Categories of Data Collected
1. Personal Identification Data: Name, username, date of birth, and contact information
(email, phone number).
2. Account Information: Login credentials, security questions, and activity logs related to
platform interactions.
3. Financial Data: Bank account details, payment method information, and transaction history
for subscriptions, tips, PPV content, etc.
4. Content Data: Photos, videos, messages, and any media uploaded or exchanged on the
platform, including the discovery page's YouTube-style shorts video feed.
5. Usage Data: Device information (IP address, browser type, operating system), login times,
platform usage patterns, and interactions with content (e.g., likes, comments, shares).
6. Communication Data: Any communications exchanged with our support team or other
users.
7. Location Data: When allowed by users, we collect geographic location for optimized
services, fraud prevention, and legal compliance.
1.2 How We Collect Data
Data may be collected through:
- Account creation and profile setup.
- Engagement with content (e.g., subscriptions, tips, DM interactions, PPV content).
- Participation in the YouTube-style short video discovery feed.
- Use of the FansClique wallet and payment system.
- Communication with FansClique’s customer support.

2. Legal Basis for Processing Data
We process data on several legal grounds, including:
- Consent: You provide consent when signing up and using our services.
- Contractual Obligation: Data is necessary for fulfilling our agreement with you, such as
processing payments and providing access to content.
- Legitimate Interests: We have a legitimate interest in maintaining the security and performance
of the platform, as well as providing a personalized experience.
- Legal Compliance: We process data to comply with applicable laws, including tax laws, anti-
money laundering regulations, and age verification requirements.

3. Data Usage
FansClique uses your personal data to:
- Provide platform services, including managing subscriptions, payments, and content sharing.
- Ensure secure communication and interactions between users (creators and fans).
- Improve the platform experience through user analytics and feedback.
- Prevent fraud, abuse, and other harmful activities.
- Comply with legal obligations related to age verification, anti-money laundering, and other
relevant regulations.
- Market platform features, updates, or promotions to users based on their interests, with
appropriate opt-out options.
Data-Driven Features:
- YouTube style shorts Discovery Feed: Data about your content engagement (likes, etc.) is
used to tailor the feed to highlight creators and content that align with user preferences.
- Clout-Based Pricing System: Data collected on interactions and user metrics informs dynamic
pricing features, such as super creator status.

4. Data Sharing and Disclosure
FansClique respects your privacy and does not sell personal data to third parties. However, we
may share your data in the following circumstances:
- Payment Processors: We share your financial information with third-party payment gateways
(such as Flutterwave GTCO, Bani, Monnify, Stripe connect or PayPal) to process
transactions, tips, or subscriptions.
- Service Providers: We may share limited data with trusted third-party service providers that
assist in providing our services (such as cloud hosting, customer support tools, etc.).
- Legal Obligations: If required by law, we will share data with regulators, law enforcement, or
other government bodies.
- Business Transfers: In case of mergers, acquisitions, or the sale of FansClique, personal data
may be transferred to new owners, but you will be notified of any such changes.

5. Data Storage and Retention
5.1 Storage Locations
Your data is stored on secure servers located in data centers within regions that adhere to
international data protection standards. Depending on your location, we may store your data on
servers within or outside your country.

5.2 Data Retention
We retain personal data for the following periods:
- Account Data: Retained until you deactivate your account or request deletion.
- Payment Data: Kept for up to 7 years in line with legal requirements for financial records.
- Content Data: Retained as long as you use the platform unless removal is requested or
necessary for legal reasons.
- Usage Data: Kept for as long as necessary to ensure the security and performance of the
platform.

6. Data Security
We implement robust security measures to protect your data, including:
- Encryption: All personal data is encrypted during transmission (SSL) and at rest.
- Access Controls: Only authorized personnel can access sensitive personal data.
- Anonymization: Where possible, data is anonymized or pseudonymized to enhance privacy.
- Regular Audits: We conduct regular security audits and vulnerability testing to detect and
respond to any potential risks.
In the unlikely event of a data breach, we will notify affected users and authorities as required by
law.

7. Your Data Rights
FansClique respects your rights regarding your personal data, which may vary
depending on your jurisdiction.
7.1 GDPR Rights (EU Users)
- Right to access your data.
- Right to rectification of inaccurate data.
- Right to erasure (right to be forgotten).
- Right to restrict processing or object to data use.
- Right to data portability.
7.2 CCPA Rights (California Users)
- Right to know what personal data is collected and how it is used.
- Right to request deletion of personal data.
- Right to opt-out of the sale of personal data (FansClique does not sell data).
7.3 POPIA Rights (South African Users)
- Right to access personal data.
- Right to correct or delete personal data.
- Right to object to processing of personal data.
7.4 NDPR Rights (Nigerian Users)
- Right to access personal data and request corrections.
- Right to delete or withdraw consent for data use.
7.5 African Data Protection Laws
FansClique complies with data protection regulations across multiple African countries.
Depending on your location, you may have similar rights under:
- Kenya Data Protection Act (DPA)
- Ghana Data Protection Act (Act 843)
- Mauritius Data Protection Act.
- Tunisian Law on Personal Data Protection.
- Moroccan Law No. 09-08.
- Egypt Personal Data Protection Law (PDPL)
You can submit requests to exercise these rights by contacting us at [email protected]

8. Cross-Border Data Transfers
FansClique operates internationally and may transfer data across borders to ensure platform
functionality. We use appropriate safeguards, such as Standard Contractual Clauses (SCCs),
to ensure your personal data is protected during international transfers in compliance with the
GDPR,NDPR, POPIA and other local laws.

9. Data Protection Officer (DPO)
To ensure ongoing compliance with global data protection laws, FansClique has appointed a
Data Protection Officer (DPO). You may contact our DPO for any concerns regarding your data
at:
Email: [email protected]

10. Updates to the Data Policy
FansClique reserves the right to update this Data Policy from time to time to reflect changes in
data collection practices or legal requirements. We will notify you of any significant updates
through email or platform notifications.
The latest version of this policy will always be available on our website

11. Contact Information
If you have any questions or concerns about this Data Policy or how your personal information
is handled, please contact us at:

13. Changes to This Privacy Policy
FansClique may update this Privacy Policy from time to time to reflect changes in our practices
or applicable law. We will notify you of significant changes via email or platform notifications.
The latest version of the Privacy Policy will always be available on our website.

13. Contact Information
If you have any questions about this Privacy Policy, or how your data is handled, please contact
us at:
- Email: [email protected]