FansClique Privacy Policy

 

Effective Date:25 August 2025

 

FansClique Privacy Policy

(Operated by Meritearn Ltd., Company No. 16645155, 61 Bridge Street, Kingston, HR5 3DJ, United Kingdom)

 

 

1 – Introduction & Scope

1.1 Who We Are

This Privacy Policy (“Policy”) explains how Meritearn Ltd. (“Meritearn,” “we,” “our,” or “us”), the company that owns and operates the FansClique platform (“FansClique,” the “Service,” or the “Platform”), collects, uses, stores, shares, and protects your personal information when you use FansClique.

FansClique is an online digital platform at https://fansclique.com  and  enables registered users to publish, share, and monetize creative content within a safe and structured environment. By creating an account, accessing our website or services, or interacting with the platform in any way, you agree to the terms of this Privacy Policy.

1.2 Purpose of This Privacy Policy

The purpose of this Policy is to:

• Provide transparency about the categories of personal data we collect.
   
• Explain how and why we process such data.
   
• Inform you of your legal rights and choices.
   
• Describe the security and privacy safeguards we maintain.
   
• Ensure compliance with the UK Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR), and other applicable global data protection laws.
   

This Privacy Policy is designed to be read alongside our Terms of Service, which sets out the general rules and obligations of using the FansClique platform.

1.3 Scope of Application

This Policy applies to:

• All registered FansClique users (“Creators” and “Subscribers”).
   
• Visitors accessing or browsing the FansClique website.
   
• Any third parties who engage with FansClique services (e.g., payment partners, affiliates, or service providers).
   

This Policy does not apply to:

• Third-party websites or platforms linked from FansClique.
   
• Services offered by independent creators outside of the FansClique platform.
   
• Data processing activities undertaken solely by external service providers (e.g., PayPal, Stripe, or other payment gateways), which are subject to their own privacy policies.
   

1.4 Definitions

For the purposes of this Privacy Policy:

• “Personal Data” means any information that can directly or indirectly identify you, such as your name, email address, financial details, or device information.
   
• “Processing” refers to any operation performed on personal data, whether automated or not, such as collection, storage, use, disclosure, or deletion.
   
• “Data Controller” is Meritearn Ltd., the legal entity determining the purpose and means of processing your personal data.
   
• “Data Processor” refers to any third party that processes personal data on our behalf.
   
• “Applicable Laws” means all relevant privacy and data protection laws, including the UK GDPR, the UK Data Protection Act 2018, and guidance from the UK Information Commissioner’s Office (ICO).
   

1.5 Binding Nature

By accessing or using FansClique, you:

• Confirm that you have read and understood this Privacy Policy.
   
• Consent to the collection and use of your data as described herein.
   
• Acknowledge that continued use of FansClique after updates to this Policy constitutes acceptance of the revised terms.
   

2  Data We Collect

2.1 Overview

When you use FansClique, we collect a range of personal and non-personal information to provide services, ensure compliance, maintain security, and improve the user experience. The categories of data collected depend on your role (Creator, Subscriber, or Visitor), how you use the platform, and your account settings.

2.2 Categories of Data Collected

(a) Account & Identity Data

When you register for a FansClique account, we may collect:

• Full name and username.
   
• Date of birth (to verify age eligibility).
   
• Email address and contact information.
   
• Passwords and security credentials.
   
• Proof of identity (passport, national ID, driver’s license) for verification purposes.
   
• Selfie images or videos (used for age and identity verification).
   

(b) Contact & Communication Data

• Email communications with our support team.
   
• Notifications preferences and message settings.
   
• Records of correspondence for customer service, dispute resolution, and compliance checks.
   

(c) Payment & Financial Data

To process subscriptions, tips, pay-per-view content, and payouts:

• Bank account or payout details.
   
• Credit/debit card information (processed securely through third-party payment providers such as Stripe, PayPal, or similar).
   
• Billing address.
   
• Transaction records, amounts, and timestamps.
   

FansClique does not directly store full card or bank details — these are encrypted and processed via our payment partners.

(d) User-Generated Content Data

Creators and Subscribers may upload, publish, or share:

• Photos, videos, stories, and other digital files.
   
• Captions, comments, messages, and metadata associated with uploads.
   
• Content categorization and tagging (used for discovery and search features).
   

(e) Technical & Device Data

We automatically collect information from your device when you use FansClique:

• Device type (mobile, desktop, tablet).
   
• Operating system and version.
   
• Browser type and version.
   
• IP address and approximate location (city/country).
   
• Device identifiers and advertising IDs.
   
• Log files, crash reports, and diagnostic data.
   

(f) Usage & Activity Data

We collect information on how you interact with FansClique:

• Login timestamps and activity sessions.
   
• Navigation patterns, including pages viewed and content engaged with.
   
• Features used (e.g., messaging, subscriptions, tipping).
   
• Referral links or affiliate sources.
   
• Frequency and duration of platform use.
   

(g) Cookies & Tracking Technologies

FansClique uses cookies, web beacons, pixels, and similar technologies to:

• Authenticate users and maintain sessions.
   
• Remember preferences and settings.
   
• Analyze site traffic and performance.
   
• Deliver personalized recommendations and targeted marketing.
   

Users may manage or disable cookies via their browser settings, though some features of FansClique may not function properly if cookies are disabled.

(h) Legal & Compliance Data

To meet regulatory and legal obligations, we may collect:

• Identity documents and verification checks for AML/KYC compliance.
   
• Records of suspicious activity or policy violations.
   
• Law enforcement requests, subpoenas, or other legal documentation.
   

 

2.3 Data You Choose Not to Provide

Where data is optional (e.g., profile customization), you may decline to provide it. However, some data (e.g., identity verification, payment details) is mandatory for access to certain features. Without such information, FansClique may restrict your use of the platform.

 

2.4 Accuracy of Data Provided

You are responsible for ensuring that the data you provide to FansClique is accurate, up-to-date, and complete. Providing false, misleading, or incomplete data may result in suspension or termination of your account.

3 – How We Use Your Data

3.1 Overview

FansClique processes personal data in strict accordance with UK GDPR, the Data Protection Act 2018, and other applicable laws. Our primary goal is to provide a secure, functional, and transparent platform for creators and subscribers, while upholding user privacy and compliance obligations.

3.2 Purposes of Processing

We use your personal data for the following purposes:

(a) Account Creation & Management

• To register and verify new users.
   
• To authenticate logins and secure access.
   
• To manage user profiles, preferences, and account settings.
   

(b) Platform Operation

• To enable creators to upload, publish, and monetize content.
   
• To allow subscribers to access, view, and interact with content.
   
• To facilitate tips, subscriptions, and pay-per-view transactions.
   
• To enable direct messaging and community features.
   

(c) Payment Processing

• To process subscription fees, tips, and other transactions.
   
• To issue payouts to creators.
   
• To prevent fraud, chargebacks, and unauthorized transactions.
   

Payment data is processed securely via trusted third-party providers (e.g., Stripe, PayPal).

(d) Safety & Compliance

• To verify user identity and age eligibility (18+ only).
   
• To enforce platform rules, Terms of Service, and community guidelines.
   
• To detect, investigate, and prevent illegal or prohibited activities (e.g., child exploitation, financial crime, hate content).
   
• To comply with Anti-Money Laundering (AML) and Know Your Customer (KYC) obligations.
   

(e) Customer Support

• To respond to inquiries, troubleshoot issues, and handle complaints.
   
• To provide technical support and resolve disputes.
   
• To maintain records of communications for training and compliance purposes.
   

(f) Platform Improvement

• To monitor site performance and optimize usability.
   
• To test new features and enhance user experience.
   
• To analyze trends, usage patterns, and market demand.
   

(g) Marketing & Communications

• To send service updates, security alerts, and important notices.
   
• To deliver marketing messages (where legally permitted and subject to opt-in consent).
   
• To personalize user experience through recommendations and targeted promotions.
   

3.3 Lawful Bases for Processing

FansClique processes data under the following lawful bases as defined by the UK GDPR:

• Consent: Where you explicitly agree to data processing (e.g., marketing communications, cookie tracking).
   
• Contractual Necessity: To fulfill our contractual obligations (e.g., processing payments, providing platform access).
   
• Legal Obligation: To comply with applicable laws (e.g., AML/KYC checks, tax reporting).
   
• Legitimate Interests: To improve services, enhance security, and grow the platform, provided such interests do not override your rights.
   
• Vital Interests: In rare cases, to protect an individual’s safety or well-being.
   

3.4 Automated Decision-Making

In limited circumstances, FansClique may use automated tools to:

• Detect fraudulent transactions.
   
• Flag prohibited content.
   
• Monitor suspicious activity patterns.
   

These systems are regularly audited to ensure fairness, accuracy, and accountability. Users may request human review of automated decisions where legally required.

3.5 Prohibited Uses of Data

FansClique does not:

• Sell your personal data to third parties.
   
• Use personal data for unrelated advertising without your consent.
   
• Collect unnecessary sensitive data such as religious beliefs, sexual orientation, or political affiliations, unless legally required for compliance.
   

4 – How We Share Your Data

4.1 General Principle

FansClique treats your personal data as confidential. We only share it with trusted third parties where necessary to:

• Provide services,
   
• Fulfill legal obligations,
   
• Protect our users, or
   
• Operate the platform securely.
   

We never sell, rent, or trade your personal data.

4.2 Categories of Third Parties

(a) Payment Processors

We share financial and transaction data with regulated payment providers such as:

• Stripe (for subscription payments and payouts).
   
• PayPal (for eligible transactions).
   
• Other licensed payment service providers, depending on user geography.
   

These providers process payments, verify financial data, and ensure compliance with AML/KYC rules.

(b) Identity Verification Services

For security and compliance, FansClique works with verification vendors to confirm:

• User identity.
   
• Age eligibility (18+ requirement).
   
• Authenticity of government-issued documents.
   

This data is securely transmitted and stored only as long as necessary for verification purposes.

(c) Analytics & Security Tools

We use third-party analytics and monitoring tools to:

• Track website performance.
   
• Identify bugs and crashes.
   
• Monitor suspicious or fraudulent activity.
   

These services process technical and usage data but cannot access your personal communications or private content.

(d) Cloud Hosting & Infrastructure Providers

FansClique relies on secure hosting partners to store and process platform data, including user content. Providers are contractually bound to:

• Maintain strict confidentiality.
   
• Implement industry-standard security measures.
   
• Store data in compliance with applicable data protection laws.
   

(e) Regulatory & Legal Authorities

We may disclose personal data to public authorities if legally required or permitted, including:

• Law enforcement agencies (e.g., criminal investigations).
   
• Tax authorities (e.g., financial reporting).
   
• Regulators or courts under lawful orders or subpoenas.
   

Disclosures are made only to the extent necessary and in line with due process.

(f) Corporate Transactions

In the event of a business transaction such as a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the successor entity. We will notify users in advance where legally required.

4.3 International Data Transfers

FansClique operates globally, which means your data may be transferred outside the UK/EEA. Where this occurs:

• Transfers are limited to countries with adequate data protection safeguards (recognized under UK GDPR), or
   
• Transfers are protected by standard contractual clauses (SCCs) or equivalent mechanisms approved by regulators.
   

 

4.4 Confidentiality Obligations

All third parties that process user data on our behalf must:

• Sign binding data processing agreements.
   
• Limit processing to specified purposes.
   
• Maintain strong data security safeguards.
   
• Delete or anonymize data once no longer required.
   

4.5 No Unauthorized Sharing

FansClique will never:

• Sell your personal information to advertisers.
   
• Share your private communications without your consent, except as required by law.
   
• Allow partners to repurpose data for unrelated commercial use.

5 – Data Retention

5.1 General Principle

FansClique retains personal data only for as long as is necessary to:

• Provide the services you request,
   
• Comply with legal, accounting, or regulatory obligations,
   
• Resolve disputes,
   
• Enforce our agreements and community standards, and
   
• Maintain the integrity and safety of the platform.
   

Once data is no longer needed for these purposes, it is securely deleted or anonymized.

5.2 Retention Periods by Category

(a) Account & Identity Data

• Retained while your account remains active.
   
• Upon account closure, retained for up to 6 years to comply with anti-fraud, AML/KYC, and recordkeeping obligations.
   
• Verification documents may be retained longer where legally mandated by regulators.
   

(b) Contact & Communication Data

• Support requests, complaints, and correspondence are retained for up to 5 years from the date of resolution.
   
• Helps us maintain a record of interactions for compliance and training purposes.
   

(c) Payment & Financial Data

• Transaction data is retained for at least 6 years in compliance with tax and accounting regulations.
   
• Sensitive payment details (e.g., credit/debit card numbers) are not stored by FansClique, but by secure third-party payment providers.
   

(d) User-Generated Content

• Content remains available as long as your account is active or until you choose to delete it.
   
• Upon account deletion, residual backups of content may persist for up to 12 months in secure archives before permanent deletion.
   

(e) Technical & Usage Data

• Log files, IP addresses, and activity data are retained for 12 to 24 months, unless longer retention is required for fraud prevention or regulatory investigations.
   

(f) Legal & Compliance Data

• Records of AML/KYC checks, suspicious activity reports, and compliance-related data may be retained for up to 10 years depending on jurisdictional requirements.
   

5.3 Account Closure Requests

If you delete or deactivate your FansClique account:

• Some data will be retained for regulatory and fraud-prevention purposes.
   
• Personal data not subject to mandatory retention will be securely deleted within 30–90 days.
   
• Certain anonymized or aggregated data may continue to be used for statistical or research purposes, without identifying you personally.
   

5.4 Exceptions to Retention Periods

In rare cases, we may retain data longer if:

• Required by law or court order.
   
• Necessary for an ongoing investigation or dispute.
   
• Needed to protect the rights, property, or safety of FansClique, its users, or third parties.
   

5.5 Data Deletion & User Rights

Users may request data deletion under applicable privacy laws (UK GDPR, NDPR, CCPA, etc.). Upon verification:

• Non-essential data will be deleted within a reasonable timeframe.
   
• Certain categories of data may still be retained where legally mandated.
   
• Confirmation of deletion or explanation of lawful retention will be provided to the user.

6 – Data Security & Protection Measures

6.1 Commitment to Security

FansClique and its parent company, Meritearn Ltd., are fully committed to safeguarding the confidentiality, integrity, and availability of your personal data. We employ technical, organizational, and administrative measures designed to protect information against unauthorized access, alteration, disclosure, or destruction.

6.2 Technical Safeguards

• Encryption: All sensitive data, including financial and identity information, is encrypted in transit (TLS/SSL) and at rest using industry-standard encryption protocols.
   
• Firewalls & Intrusion Detection: Network firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) monitor for malicious activity.
   
• Access Controls: Strict role-based access controls ensure that only authorized personnel can access sensitive data.
   
• Anonymization & Pseudonymization: Where possible, data is de-identified to minimize risks in the event of a breach.
   
• Secure Hosting: Our infrastructure providers are ISO 27001 certified or equivalent, and comply with GDPR/UK GDPR hosting requirements.
   

6.3 Organizational Safeguards

• Data Protection Officer (DPO): FansClique has designated a DPO to oversee compliance with privacy laws and internal security practices.
   
• Staff Training: Employees and contractors handling data undergo mandatory training on cybersecurity, privacy, and responsible data handling.
   
• Access Auditing: Logs of administrative access to sensitive systems are maintained and reviewed regularly.
   
• Third-Party Vendor Due Diligence: Partners (e.g., payment processors, hosting providers) are vetted for compliance with security and privacy obligations.
   

6.4 Procedural Safeguards

• Multi-Factor Authentication (MFA): Mandatory for administrative accounts and available for users to enhance login security.
   
• Regular Security Testing: Penetration testing, vulnerability scans, and security audits are performed periodically.
   
• Incident Response Plan: FansClique maintains a formal procedure to detect, contain, and remediate security incidents promptly.
   
• Data Minimization: We collect and retain only the data necessary for lawful and operational purposes.
   

6.5 User Responsibilities

While FansClique takes significant measures to protect your information, users also play a role in safeguarding their accounts. You agree to:

• Use strong, unique passwords and update them regularly.
   
• Enable two-factor authentication (2FA) where available.
   
• Keep login credentials confidential and not share them with others.
   
• Immediately notify FansClique at [email protected] if you suspect unauthorized use of your account.
   

6.6 Breach Notification

In the unlikely event of a data breach:

• FansClique will notify affected users without undue delay if their rights and freedoms are at high risk.
   
• We will also notify the UK Information Commissioner’s Office (ICO) and other regulators as required by law.
   
• Remedial steps will be taken to contain the breach and prevent recurrence.
   

6.7 No Absolute Security Guarantee

While we implement industry-leading measures, no online system is 100% secure. FansClique cannot guarantee absolute security but commits to taking all reasonable and proportionate steps to minimize risks.

 

Perfect — here’s Part 7 – Your Privacy Rights of the FansClique Privacy Policy, fully expanded in compliance with UK GDPR, EU GDPR, NDPR (Nigeria), and CCPA (California) frameworks:

7 – Your Privacy Rights

FansClique respects and upholds the privacy rights of all users, regardless of jurisdiction. Depending on your location, you may be entitled to specific rights under applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the EU GDPR, the Nigerian Data Protection Regulation (NDPR), and the California Consumer Privacy Act (CCPA).

7.1 General Rights Available to All Users

As a FansClique user, you have the following fundamental rights regarding your personal data:

• Right to Access: You may request confirmation of whether FansClique processes your personal data, and obtain a copy of such data.
   
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
   
• Right to Erasure (“Right to be Forgotten”): You may request deletion of your personal data, subject to legal or contractual obligations requiring retention.
   
• Right to Restrict Processing: You may request a temporary halt to the processing of your personal data in certain circumstances (e.g., pending verification of accuracy).
   
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, and machine-readable format for transfer to another provider.
   
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
   

7.2 Additional Rights under GDPR/UK GDPR

If you are located in the United Kingdom or European Union, you also have the following rights:

• Right to Object: You may object at any time to processing of personal data based on legitimate interests or for direct marketing.
   
• Automated Decision-Making & Profiling: You have the right not to be subject to decisions based solely on automated processing, including profiling, which significantly affect you. FansClique does not engage in automated decisions without human involvement.
   

7.3 Rights under NDPR (Nigeria)

For Nigerian residents under the NDPR framework:

• You are entitled to all rights outlined above (access, rectification, deletion, restriction, portability, and consent withdrawal).
   
• FansClique will ensure your data is processed in line with Nigerian Information Technology Development Agency (NITDA) requirements.
   
• Complaints may be escalated to the NITDA if you are unsatisfied with FansClique’s handling of your data.
   

7.4 Rights under CCPA (California, USA)

If you are a California resident, the CCPA grants you additional rights:

• Right to Know: You may request details about categories of personal data collected, sources of collection, purposes of use, and categories of third parties with whom we share your data.
   
• Right to Delete: You may request that we delete your personal information, subject to certain exceptions (e.g., fraud prevention, compliance with law).
   
• Right to Opt-Out of Sale: FansClique does not sell your personal information. Should that change, we will provide an opt-out mechanism.
   
• Right to Non-Discrimination: You will not face discrimination (e.g., denial of services, different pricing) for exercising your privacy rights.
   

7.5 Exercising Your Rights

• To exercise any of your privacy rights, please contact us at [email protected].
   
• We may require verification of your identity before processing requests, including government-issued identification where necessary.
   
• We will respond within statutory timelines (generally 30 days under GDPR/UK GDPR/NDPR, and 45 days under CCPA).
   

7.6 Complaints

If you believe FansClique has infringed your data rights:

• UK users may contact the Information Commissioner’s Office (ICO) at https://ico.org.uk.
   
• EU users may contact their local Data Protection Authority.
   
• Nigerian users may escalate concerns to NITDA at https://nitda.gov.ng.
   
• California users may contact the California Attorney General’s Office.
   

8 – Data Retention & Deletion Policy

FansClique is committed to retaining personal data only for as long as necessary to fulfill the purposes for which it was collected, in compliance with applicable legal, regulatory, contractual, and operational obligations.

8.1 General Retention Principles

• We retain personal data only as long as required to:
   
  • Provide and maintain access to the FansClique platform.
     
  • Comply with applicable laws and regulations (including tax, AML, and record-keeping obligations).
     
  • Resolve disputes, enforce agreements, and protect FansClique against legal claims.
     
• When personal data is no longer necessary, FansClique will ensure it is securely deleted, anonymized, or aggregated in a way that prevents identification.
   

8.2 Specific Retention Periods

• Account Information: Retained for the duration of your account’s active use. Upon closure, basic account details may be retained for up to 6 years for compliance with tax, legal, or regulatory requirements.
   
• Payment and Financial Data: Retained for 7 years, in line with anti-money laundering (AML), fraud prevention, and financial regulations.
   
• Communication Records (support tickets, correspondence, user complaints): Retained for up to 3 years to evidence dispute resolution and customer service history.
   
• Content Uploaded by Users: Retained for as long as the content remains published or until the user deletes it. Upon deletion, FansClique will remove content from active systems but may keep backup copies for 90 days in disaster recovery archives.
   
• Technical Logs & Security Data: Retained for up to 12 months unless required longer for security investigations, fraud prevention, or system improvement.
   
• Marketing Preferences: Retained until you opt out or withdraw consent.
   

8.3 Data Deletion Process

• When you delete your account, FansClique initiates a two-step deletion process:
   
  1. Deactivation Phase: Account is deactivated and inaccessible to others.
      
  2. Final Deletion Phase: After 30 days, data is permanently deleted unless retention is required by law.
      
• Deleted data may persist temporarily in secure backup archives but will not be restored to active use.
   

8.4 Exceptions to Immediate Deletion

FansClique may retain certain data even after a deletion request if necessary to:

• Comply with a legal or regulatory requirement (e.g., AML and tax obligations).
   
• Investigate fraud, abuse, or security incidents.
   
• Protect FansClique’s rights or the rights of other users.
   
• Enforce agreements and resolve disputes.
   

8.5 Anonymization and Aggregation

Where possible, FansClique will anonymize or aggregate personal data so that it is no longer identifiable. Such anonymized data may be retained indefinitely for statistical analysis, research, business intelligence, or system improvement purposes.

8.6 User Rights Regarding Retention

• Users may request early deletion of their data by contacting [email protected].
   
• We will review all deletion requests against applicable retention obligations and provide a clear response.
   
• In jurisdictions with statutory retention limits (e.g., GDPR, NDPR, CCPA), FansClique will ensure compliance with the shortest permissible period.
   

9 – Data Sharing & Disclosure

FansClique respects the confidentiality of your personal data. We will never sell, rent, or trade your information for marketing purposes. However, we may share limited data under carefully defined circumstances to operate the platform effectively, comply with laws, and protect the safety and integrity of our users.

9.1 Sharing with Service Providers (Processors)

We engage trusted third-party service providers who perform services on our behalf, including:

• Payment processors and banking partners (e.g., Stripe, PayPal, Payoneer, local banking institutions) to facilitate secure transactions and verify compliance with AML/CFT laws.
   
• Cloud hosting and infrastructure providers to ensure platform reliability, scalability, and security.
   
• Analytics, anti-fraud, and security monitoring services to detect and prevent abuse, fraud, and unauthorized access.
   
• Customer support platforms to manage and respond to inquiries efficiently.
   

These providers may only process data under strict contractual agreements and must comply with applicable data protection regulations.

9.2 Sharing with Legal & Regulatory Authorities

FansClique may disclose data where required to:

• Comply with applicable laws, regulations, or legal proceedings (e.g., tax filings, AML checks, NDPR/GDPR compliance, or regulatory inquiries).
   
• Respond to lawful requests from government agencies, financial regulators, or law enforcement authorities.
   
• Enforce our Terms of Service or protect the safety and rights of FansClique, its users, or the public.
   

9.3 Business Transfers

If FansClique undergoes a merger, acquisition, restructuring, or sale of assets, user data may be transferred to the acquiring entity as part of due diligence or business continuation. In such cases, FansClique will ensure the new entity continues to uphold this Privacy Policy or equivalent protections.

9.4 Sharing with Professional Advisors

We may share limited personal data with auditors, legal advisors, tax consultants, or compliance officers to:

• Meet regulatory requirements.
   
• Conduct financial or operational audits.
   
• Ensure corporate governance and accountability.
   

9.5 Sharing with Other Users

Certain elements of your profile or activity on FansClique may be visible to other users, such as:

• Username, profile information, and uploaded content.
   
• Engagement metrics (likes, subscriptions, tips, comments).
  You control what you share publicly and may adjust your visibility settings.
   

9.6 International Data Transfers

Where FansClique shares personal data outside the United Kingdom, EU/EEA, or Nigeria, we ensure adequate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the UK ICO and European Commission.
   
• Verification that the recipient country ensures an adequate level of protection.
   
• Technical measures such as encryption and pseudonymization.
   

9.7 Prohibited Data Disclosure

FansClique will never:

• Sell user data for advertising or marketing purposes.
   
• Share data with unauthorized third parties.
   
• Disclose sensitive personal data (such as financial or identification documents) unless legally required or strictly necessary for fraud prevention and AML compliance.
   

9.8 Transparency of Sharing

We maintain an internal Data Sharing Register that records all categories of data shared, recipients, purposes, and legal bases for sharing. This ensures accountability and transparency, available to regulators upon request.

10 – International Data Transfers & Safeguards

FansClique operates as a global platform with users, service providers, and partners located in multiple jurisdictions. As a result, your personal data may be transferred to, stored in, or accessed from countries outside your country of residence, including outside the United Kingdom, European Union/EEA, and Nigeria.

We are committed to ensuring that such transfers are lawful, secure, and provide an adequate level of protection consistent with applicable data protection regulations.

10.1 Legal Bases for International Transfers

Where we transfer personal data across borders, we rely on one or more of the following safeguards:

• Adequacy Decisions: Transfers to countries recognized by the UK ICO or European Commission as providing adequate data protection.
   
• Standard Contractual Clauses (SCCs): Contractual safeguards approved by regulators ensuring recipients provide protections equivalent to UK GDPR/EU GDPR.
   
• International Data Transfer Agreements (IDTAs): For transfers under UK law when SCCs are insufficient.
   
• User Consent: In limited cases, we may request your explicit consent for a specific transfer, after informing you of potential risks.
   

10.2 Transfers to the United States and Other Third Countries

Where FansClique engages service providers or partners based in the United States or other non-adequate jurisdictions, we ensure compliance through:

• Execution of SCCs and UK IDTAs.
   
• Additional technical safeguards, including encryption of data in transit and at rest.
   
• Rigorous vetting of vendor compliance with industry best practices (e.g., ISO 27001, SOC 2).
   

10.3 Nigerian Data Protection (NDPR) Transfers

For users located in Nigeria, FansClique complies with the Nigeria Data Protection Regulation (NDPR) by ensuring:

• Data transfers occur only where adequate protections exist.
   
• Cross-border transfers are documented in a Data Protection Impact Assessment (DPIA).
   
• Where transfers are necessary for contract performance (e.g., payment settlement through international processors), legal and technical safeguards are applied.
   

10.4 Safeguards for Sensitive Data

When transferring sensitive categories of personal data (e.g., identity verification documents, payment data), FansClique applies heightened safeguards, including:

• Data minimization and pseudonymization before transfer.
   
• Multi-factor authentication and restricted access controls.
   
• Secure transmission protocols (TLS 1.3, VPN tunnels).
   

10.5 User Rights on International Transfers

You have the right to:

• Request a copy of the safeguards (such as SCCs or IDTAs) used for your data transfers.
   
• Be informed of the specific jurisdictions to which your data is transferred.
   
• Withdraw consent where transfers are based solely on consent.
   

Requests may be made to [email protected].

 

10.6 Transparency Commitment

FansClique will maintain an updated International Transfer Register documenting:

• Categories of data transferred.
   
• Destination countries.
   
• Legal bases and safeguards applied.
  This record will be made available to regulators upon request.

11 – User Rights & Control Over Data

FansClique is committed to empowering users with control over their personal data. Depending on your place of residence, you may have specific rights under applicable laws such as the UK GDPR, EU GDPR, Nigeria Data Protection Regulation (NDPR), or the California Consumer Privacy Act (CCPA). We respect these rights and provide clear mechanisms for exercising them.

11.1 Right of Access

You may request confirmation as to whether we process your personal data and obtain a copy of such data, including details on:

• The categories of personal data held.
   
• The purposes of processing.
   
• The recipients or categories of recipients to whom data has been disclosed.
   
• The envisaged retention period.
   

11.2 Right to Rectification

You have the right to request correction of inaccurate personal data and completion of incomplete data. Updates can often be made directly through your account settings.

11.3 Right to Erasure (“Right to Be Forgotten”)

You may request deletion of your personal data where:

• It is no longer necessary for the purposes for which it was collected.
   
• You withdraw consent (where consent was the legal basis).
   
• You object to processing and there are no overriding legitimate grounds.
   
• Processing was unlawful or required to comply with a legal obligation.
   

Note: FansClique may retain certain data where legally required (e.g., AML obligations, financial records).

11.4 Right to Restriction of Processing

You may request limitation of processing of your data where:

• Accuracy of the data is contested.
   
• Processing is unlawful and you prefer restriction instead of erasure.
   
• Data is no longer needed but required for legal claims.
   
• You object to processing and verification of overriding grounds is pending.
   

11.5 Right to Data Portability

You may request a structured, commonly used, and machine-readable copy of your personal data and transfer it to another service provider where:

• Processing is based on your consent or contract.
   
• Processing is carried out by automated means.
   

11.6 Right to Object

You may object at any time to processing of your personal data where processing is based on:

• Legitimate interests pursued by FansClique or third parties.
   
• Direct marketing purposes (including profiling).
   

We will cease such processing unless we demonstrate compelling legitimate grounds or it is required for legal claims.

11.7 Rights Relating to Automated Decision-Making & Profiling

FansClique does not make decisions based solely on automated processing that produce legal or similarly significant effects. Where profiling is used (e.g., fraud prevention, account safety), you have the right to request human review.

11.8 Rights Under CCPA (California Residents)

California residents have the following additional rights:

• Right to Know what categories and specific pieces of personal data are collected, used, disclosed, or sold.
   
• Right to Opt-Out of the sale of personal data (FansClique does not sell personal data).
   
• Right to Non-Discrimination for exercising privacy rights.
   

11.9 Exercising Your Rights

• Requests may be submitted to [email protected].
   
• FansClique may require identity verification before fulfilling requests.
   
• We will respond within 30 days (extendable to 90 days for complex requests, with notification).
   
• Requests are free of charge, except where manifestly unfounded, excessive, or repetitive.
   

11.10 Limitations

Your rights may be limited where:

• Data must be retained for compliance with legal or regulatory obligations.
   
• Disclosure would adversely affect the rights or freedoms of others.
   
• Requests conflict with AML, fraud prevention, or law enforcement requirements.

12 – Cookies & Tracking Technologies

FansClique uses cookies and similar technologies to provide, secure, and improve the platform. This section explains what these technologies are, why we use them, and your choices regarding their use.

12.1 What Are Cookies?

• Cookies are small text files placed on your device when you visit our platform.
   
• They are widely used to make websites function, operate more efficiently, and provide information to site owners.
   
• Cookies may be “session cookies” (deleted when you close your browser) or “persistent cookies” (remain on your device until they expire or are deleted).
   

12.2 Types of Cookies We Use

• Strictly Necessary Cookies
   
  • Essential for platform operation (e.g., login authentication, account security).
     
  • Without these cookies, certain features cannot function.
     
• Performance & Analytics Cookies
   
  • Collect information about how users interact with FansClique.
     
  • Used to improve website performance and user experience.
     
  • Examples: Google Analytics (IP anonymization enabled).
     
• Functionality Cookies
   
  • Remember preferences (e.g., language, region, saved settings).
     
  • Enhance personalization and usability.
     
• Advertising & Marketing Cookies
   
  • Used (where applicable) to measure the effectiveness of campaigns.
     
  • FansClique does not sell user data to advertisers, but may use internal analytics to improve recommendations.

12.3 Other Tracking Technologies

• Web Beacons/Pixels: Tiny graphics embedded in emails or pages that monitor engagement (e.g., email open rates).
   
• Local Storage & Session Storage: Browser-based storage mechanisms for caching content and preferences.
   
• Device Fingerprinting: Security measure to detect fraud and unauthorized account access.
   

12.4 Legal Basis for Cookies

• Strictly necessary cookies: Processed under legitimate interest to deliver core services.
   
• Analytics, functionality, and marketing cookies: Processed only where users have given consent (in line with GDPR and ePrivacy Directive).
   

12.5 Consent & Cookie Banner

• Upon first visit, FansClique presents a cookie banner explaining categories of cookies.
   
• Users can:
   
  • Accept all cookies.
     
  • Reject non-essential cookies.
     
  • Customize cookie preferences.
     
• Consent is stored and may be withdrawn at any time via cookie settings.
   

12.6 Managing Cookies

• Most browsers allow you to block, delete, or restrict cookies.
   
• Disabling essential cookies may impact platform functionality.
   
• Instructions are available through browser help menus (e.g., Chrome, Firefox, Safari, Edge).
   

12.7 Third-Party Cookies

Some cookies are set by third parties, including:

• Payment providers (fraud detection, secure transactions).
   
• Analytics services (aggregated usage statistics).
   
• Content delivery networks (CDNs) (fast video and image delivery).
   

FansClique contracts third parties under strict data protection terms to prevent misuse of cookie data.

12.8 “Do Not Track” (DNT) Signals

FansClique does not currently respond to DNT browser signals, but users may control tracking preferences through cookie settings or browser configurations.

 

12.9 Updates to Cookie Policy

FansClique may update cookie practices to reflect changes in technology or law. Updates will be reflected in this Privacy Policy and, where necessary, notified via the cookie banner.

13 – Data Security & Protection Measures

FansClique prioritizes the confidentiality, integrity, and availability of personal data. We implement a layered security framework combining technical, organizational, and administrative measures designed to protect against unauthorized access, loss, misuse, disclosure, alteration, and destruction of data.

13.1 Security Governance

• FansClique maintains an internal Information Security Policy reviewed at least annually.
   
• Staff with access to personal data undergo background screening and are trained in data protection, cybersecurity, and AML compliance.
   
• Access to user data is strictly limited to personnel who require it to perform their duties (“least privilege principle”).
   

13.2 Technical Security Measures

• Encryption:
   
  • Data in transit protected using TLS 1.3 (SSL).
     
  • Data at rest encrypted using AES-256 industry standard.
     
• Network Security:
   
  • Use of firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS).
     
  • Continuous monitoring of network activity for anomalies.
     
• Access Control:
   
  • Multi-factor authentication (MFA) for administrator and staff accounts.
     
  • Role-based access management (RBAC).
     
• Data Backups & Redundancy:
   
  • Regular, encrypted backups stored securely across multiple regions.
     
  • Disaster recovery plan tested periodically.
     

13.3 Platform Security

• Secure Development Lifecycle (SDLC): All updates to the platform are peer-reviewed, tested, and scanned for vulnerabilities before deployment.
   
• Penetration Testing: External security experts conduct periodic penetration tests to identify and remediate vulnerabilities.
   
• Bug Bounty Program: Security researchers may responsibly disclose vulnerabilities for review and patching.
   
• Fraud Detection & Monitoring: Automated tools monitor transactions and accounts for unusual or fraudulent activity.
   

13.4 Organizational & Administrative Measures

• Confidentiality Agreements: All staff, contractors, and vendors handling personal data are bound by contractual confidentiality obligations.
   
• Vendor Risk Management: Third-party providers undergo security and compliance assessments before onboarding.
   
• Physical Security: Data centers hosting FansClique services implement 24/7 monitoring, biometric access controls, and environmental safeguards.
   

13.5 Incident Response & Breach Notification

• FansClique maintains an Incident Response Plan to investigate, contain, and remediate security incidents.
   
• In the event of a personal data breach:
   
  • Supervisory authorities (e.g., ICO, NDPR regulators) will be notified within 72 hours where required.
     
  • Affected users will be notified without undue delay if the breach is likely to result in a high risk to their rights and freedoms.
     
• Incident reports are logged and subject to continuous improvement reviews.
   

13.6 User Responsibility for Security

• Users are responsible for maintaining the confidentiality of their login credentials.
   
• FansClique recommends enabling two-factor authentication (2FA) where available.
   
• Users should immediately notify [email protected] if they suspect unauthorized use of their account.

13.7 Continuous Security Improvement

FansClique regularly reviews and updates its security measures to adapt to:

• Evolving cyber threats.
   
• Technological advancements.
   
• Changes in legal and regulatory requirements.

14 – Children’s Privacy & Age Restrictions

FansClique is a platform designed exclusively for adults aged 18 years and above. We take the protection of children and minors extremely seriously and enforce strict age-gating, verification, and reporting measures in line with UK GDPR, COPPA (Children’s Online Privacy Protection Act), NDPR, and international child protection frameworks.

14.1 Minimum Age Requirement

• FansClique does not knowingly collect, process, or store personal information from individuals under the age of 18.
   
• By creating an account, users affirm that they are at least 18 years old (or the applicable legal age of majority in their jurisdiction).
   

14.2 Age Verification Procedures

• KYC/AML Verification: All creators must undergo identity verification before content monetization or withdrawal, including:
   
  • Submission of valid government-issued identification.
     
  • Selfie/biometric verification to confirm liveness and prevent identity fraud.
     
• AI-driven detection tools may be used to flag suspicious activity or potential underage accounts.
   

14.3 Zero Tolerance for Child Exploitation

• FansClique has a zero-tolerance policy toward any material that depicts, promotes, or attempts to exploit minors.
   
• Any such content will be:
   
  • Immediately removed.
     
  • Reported to relevant law enforcement authorities, child protection hotlines, and regulators.
     
• Accounts involved will be permanently banned without notice.

14.4 Reporting Suspected Violations

• FansClique provides a dedicated reporting channel for suspected child exploitation or underage use: [email protected].
   
• Reports are reviewed immediately by our Trust & Safety team.
   
• Confirmed violations are escalated to local and international authorities, including the Internet Watch Foundation (IWF) and other accredited bodies.
   

14.5 Parental & Guardian Rights

• If a parent or guardian believes their child has provided personal data to FansClique in violation of this policy, they may contact us at [email protected].
   
• Upon verification, we will promptly delete such information and close the associated account.
   

14.6 International Compliance

FansClique’s child protection policies align with:

• UK GDPR & ICO Guidelines (digital services for minors).
   
• COPPA (US law) prohibiting collection of data from children under 13.
   
• NDPR (Nigeria) requiring parental consent for under- 21 processing.
   
• Interpol & Europol guidelines on online child exploitation reporting.

15 – Data Retention & Deletion Policy

FansClique retains user and creator data only for as long as necessary to provide services, meet legal and regulatory obligations, resolve disputes, and maintain platform integrity. We apply strict data lifecycle management rules to balance operational needs with user privacy rights.

15.1 General Retention Principles

• Personal data is kept only for the period required to:
   
  • Deliver FansClique’s services.
     
  • Comply with financial, tax, KYC/AML, and regulatory requirements.
     
  • Protect platform security, detect fraud, and enforce Terms of Service.
     
• When data is no longer required, it is securely deleted or anonymized.

15.2 Standard Retention Periods

• Account Information (profile details, email, preferences): Retained while the account is active.
   
• Creator Content (posts, videos, images): Stored while available on the platform; deleted upon user request or account closure (subject to legal holds).
   
• Transaction Records (payouts, subscriptions, tips): Retained for a minimum of 7 years, in line with UK HMRC, NDPR, and international financial compliance laws.
   
• KYC/AML Verification Data (IDs, selfies): Retained for at least 5 years after account closure, as required by financial regulations.
   
• Communications & Logs (DMs, support tickets, login records): Typically retained for 2 years to aid in dispute resolution and fraud detection.

15.3 Right to Erasure (“Right to Be Forgotten”)

• Users may request deletion of their personal data at any time by contacting [email protected].
   
• Upon request, FansClique will:
   
  • Delete or anonymize personal data not required for legal/regulatory compliance.
     
  • Confirm deletion within 30 days, unless an extension is required due to complexity.
     

15.4 Exceptions to Immediate Deletion

Data may be retained beyond user request if:

• Required by law or regulatory authorities (e.g., AML/CTF, tax, legal disputes).
   
• Needed to protect FansClique’s legal rights, security, or integrity.
   
• Relevant to ongoing investigations (fraud, abuse, intellectual property violations, or law enforcement inquiries).

15.5 Account Closure & Deletion Process

• Voluntary Closure: Users may delete accounts through in-app settings or by written request.
   
• Involuntary Closure: FansClique may suspend or terminate accounts for violations, retaining data as evidence for enforcement.
   
• Backup Systems: Deleted data may remain in encrypted system backups for up to 90 days before being permanently purged.
   

15.6 Anonymization & Aggregation

• When retention of identifiable data is no longer necessary, FansClique may retain anonymized or aggregated datasets for:
   
  • Service improvement.
     
  • Analytics and market research.
     
  • Fraud prevention and security enhancements.

16 – International Data Transfers & Cross-Border Compliance

FansClique operates globally, serving users and creators across multiple jurisdictions. To deliver services effectively, it may be necessary to transfer personal data outside the United Kingdom (UK), the European Economic Area (EEA), and other regions where users reside. We commit to ensuring such transfers comply with applicable data protection and cross-border privacy laws.

16.1 Legal Basis for Transfers

• UK & EU Users: Transfers of personal data outside the UK/EEA are conducted under:
   
  • The UK GDPR and the EU GDPR.
     
  • Adequacy Decisions (where the receiving country is recognized as providing adequate protection).
     
  • Standard Contractual Clauses (SCCs) or the UK International Data Transfer Agreement (IDTA).
     
• Nigerian Users: Data transfers comply with the Nigeria Data Protection Regulation (NDPR) and any successor legislation.
   
• Other Jurisdictions: We align with local data protection frameworks and international best practices.
   

16.2 Typical Transfer Scenarios

FansClique may transfer data internationally for the following purposes:

• Payment Processing: To global financial partners (e.g., Stripe, PayPal, Wise, banks) for handling payouts and subscription billing.
   
• Cloud Hosting & Storage: To secure servers operated by global providers (e.g., AWS, Azure, Google Cloud).
   
• KYC/AML Verification: To regulated third-party compliance vendors conducting identity and fraud checks.
   
• Analytics & Support Services: To service providers that assist in platform monitoring, user support, and fraud detection.
   

16.3 Safeguards in Place

FansClique applies robust safeguards to protect user data during international transfers:

• Encryption in transit and at rest.
   
• Binding contractual obligations with third parties to maintain confidentiality and security.
   
• Access limitation to authorized personnel only.
   
• Regular audits of partner compliance with UK, EU, and international privacy standards.

16.4 Cross-Border Payment Compliance

Given the financial nature of FansClique’s platform, all international transfers relating to payments and payouts are subject to:

• Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) obligations.
   
• Reporting duties to financial regulators in the UK and other jurisdictions.
   
• Cooperation with law enforcement authorities on request, where required by law.

16.5 User Rights & Transparency

• Users are informed whenever their data is processed by third parties outside their jurisdiction.
   
• Users may request details of:
   
  • Which third parties process their data.
     
  • The safeguards applied in international transfers.
     
• Requests can be made via [email protected] and will be addressed within 30 days.
   

16.6 Specific Jurisdictional Notes

• United States: Transfers are made under SCCs/IDTA with additional contractual protections.
   
• Nigeria & Africa: Compliance with NDPR and regional privacy frameworks.
   
• Other Regions: FansClique ensures adherence to local data protection rules and harmonizes them with UK GDPR obligations.

Part 17 – Children’s Privacy & Age Restrictions

FansClique is a platform designed exclusively for adults and does not knowingly collect or process personal information from individuals under the age of 18 years. Protecting children online is of the highest importance to us, and we take a zero-tolerance approach to underage use.

17.1 Minimum Age Requirement

• Users must be at least 18 years old to create an account, access, or use FansClique.
   
• By registering, users confirm that they meet this minimum age requirement.
   
• Where age verification is legally mandated, we may request supporting documents to confirm a user’s age before granting access.

17.2 No Collection of Children’s Data

• FansClique does not knowingly collect, maintain, or use personal data of anyone under 18.
   
• If we discover that we have inadvertently collected data from a minor, that data will be deleted immediately.
   
• Parents or guardians who believe their child has provided data to FansClique may contact us at [email protected] to request prompt deletion.
   

17.3 Strict Enforcement Against Underage Access

• Any account found to belong to a user under 18 will be terminated without notice.
   
• Associated payments, subscriptions, or revenue will be forfeited and not refunded.
   
• Reports of underage use will be taken seriously and investigated swiftly.
   

17.4 Content & Maturity Policy Alignment

• FansClique allows the sharing of mature content, but not illegal, harmful, or exploitative content.
   
• Any material involving minors in any way is expressly prohibited.
   
• Such material will be reported immediately to the relevant law enforcement agencies and data protection authorities.
   

17.5 Cooperation with Authorities

• FansClique fully cooperates with child protection agencies, regulators, and law enforcement bodies in investigating any suspected child exploitation.
   
• Any confirmed violation will result in permanent account bans and referral to the appropriate authorities.

17.6 User Responsibility

• Users are responsible for ensuring they meet the minimum age requirement before joining the platform.
   
• Attempting to circumvent age verification mechanisms or falsifying information constitutes a material breach of this Privacy Policy and our Terms of Service.

18 – Data Security & Breach Notification

FansClique is committed to maintaining the highest standards of data security to protect the personal information of our users, creators, and partners. We implement technical, organizational, and administrative safeguards designed to ensure confidentiality, integrity, and resilience of our systems and services.

18.1 Security Measures

We employ a multi-layered approach to security, which includes but is not limited to:

• Encryption: Personal data is encrypted both in transit (using TLS/SSL) and at rest.
   
• Access Controls: Role-based access restrictions ensure only authorized personnel can access user data.
   
• Two-Factor Authentication (2FA): Strong authentication mechanisms for internal systems and available to users.
   
• Regular Security Audits: Periodic third-party penetration tests and vulnerability assessments.
   
• Network Safeguards: Use of firewalls, intrusion detection/prevention systems, and continuous monitoring.
   
• Data Minimization: Only the minimum necessary personal data is stored, and retention is limited as per policy.
   

18.2 Internal Security Governance

• All employees and contractors undergo mandatory security and privacy training.
   
• Staff access to user data is strictly limited and monitored.
   
• Any internal breach of policy leads to disciplinary action, including termination and legal recourse.
   

18.3 Breach Detection & Response

FansClique has established a Data Breach Response Plan to address potential incidents:

1. Immediate Investigation: On detection of a suspected breach, security teams isolate affected systems.
    
2. Assessment: Determine the scope, type of data involved, and potential risk to users.
    
3. Containment: Secure systems, reset credentials, and patch vulnerabilities.
    
4. Notification:
    
   • If the breach poses a risk to user rights and freedoms, affected users will be notified without undue delay.
      
   • Relevant authorities (such as the UK Information Commissioner’s Office) will be notified within the legally required timeframe (usually 72 hours).

18.4 User Responsibilities

Users also play a key role in maintaining account security by:

• Using strong, unique passwords.
   
• Enabling two-factor authentication (2FA).
   
• Keeping login credentials private.
   
• Immediately reporting any suspected unauthorized account activity to [email protected].

18.5 Limitations

While FansClique takes robust measures to secure personal data, no system is completely immune to cyberattacks. Users acknowledge that:

• Absolute security cannot be guaranteed.
   
• FansClique cannot be held liable for breaches caused by third-party service providers outside our reasonable control, though we ensure they maintain strong protections.
   

18.6 Ongoing Commitment

We regularly review and update our data security practices to keep pace with evolving threats, regulatory requirements, and industry best practices. FansClique’s goal is to ensure trust, transparency, and resilience in safeguarding user information.

19 – Data Retention & Deletion Policy

FansClique retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes. We believe in data minimization and ensure that personal data is not stored longer than required.

19.1 General Retention Principles

• Active Accounts: We retain user data for the duration of the account’s active status.
   
• Closed Accounts: When a user account is terminated or deleted, we retain only the information necessary to:
   
  • Comply with legal, tax, and regulatory obligations.
     
  • Resolve disputes and enforce agreements.
     
  • Prevent fraud, abuse, or re-registration of banned accounts.

19.2 Specific Retention Periods

• Account Data (e.g., profile, login credentials): Retained for the lifetime of the account, then securely deleted within 12 months of closure unless legal obligations require longer storage.
   
• Payment & Transaction Records: Retained for a minimum of 6 years in accordance with UK tax and financial regulations, and global Anti-Money Laundering (AML) standards.
   
• Verification Data (KYC/AML checks): Retained for at least 5 years after account closure, as required by financial laws.
   
• Communications & Support Requests: Retained for 3 years after closure for quality assurance, legal defense, and fraud prevention.
   
• Cookies & Analytics Data: Retained for up to 24 months, after which it is anonymized or deleted.

19.3 Secure Deletion

When retention periods expire, data is securely erased using methods that prevent recovery, including:

• Permanent deletion from databases.
   
• Wiping of backups after expiry periods.
   
• Anonymization where deletion is not feasible but statistical analysis remains valuable.

19.4 User Rights to Deletion (“Right to be Forgotten”)

• Users may request deletion of their personal data at any time by contacting [email protected].
   
• Requests will be evaluated in line with:
   
  • Legal retention requirements (e.g., AML, tax laws).
     
  • Outstanding disputes, chargebacks, or fraud investigations.
     
• Where deletion is legally or contractually restricted, FansClique will explain the reasons to the user and confirm when deletion becomes possible.
   

19.5 Exceptions

FansClique may retain limited personal data for longer periods if:

• Required by law, regulatory authorities, or court order.
   
• Necessary to protect FansClique’s legal interests.
   
• Needed for ongoing investigations into platform misuse or unlawful activity.

19.6 Transparency on Retention

We publish clear retention guidelines and review them regularly to ensure they align with UK GDPR, EU GDPR, NDPR, and other international data protection requirements.

20 – User Rights & Data Subject Requests (DSARs)

FansClique is committed to respecting and upholding the rights of users as data subjects under applicable privacy and data protection laws, including the UK GDPR, EU GDPR, and NDPR. Users have the following rights regarding their personal data.

20.1 Right of Access

• Users may request confirmation of whether FansClique processes their personal data.
   
• Upon request, we will provide:
   
  • The categories of data we hold.
     
  • The purposes for which it is processed.
     
  • The recipients with whom it has been shared.
     
  • The retention periods applicable.

20.2 Right to Rectification

• Users may request correction of inaccurate or incomplete personal data.
   
• FansClique will update records promptly and notify relevant third parties (e.g., payment processors) of the correction.

20.3 Right to Erasure (“Right to be Forgotten”)

• Users may request deletion of their personal data where:
   
  • The data is no longer necessary for the purposes collected.
     
  • Consent has been withdrawn (where consent was the legal basis).
     
  • The user objects to processing and there are no overriding legitimate grounds.
     
  • The data was unlawfully processed.
     
• Exemptions: FansClique may refuse erasure if retention is required by law, for financial record-keeping, AML compliance, or defense of legal claims.
   

20.4 Right to Restrict Processing

• Users may request that processing of their data be restricted if:
   
  • They contest the accuracy of the data.
     
  • Processing is unlawful but deletion is not requested.
     
  • FansClique no longer needs the data but the user requires it for legal claims.
     
  • The user has objected to processing pending resolution.
     

20.5 Right to Data Portability

• Users may request a copy of their personal data in a structured, commonly used, machine-readable format.
   
• Where technically feasible, users may request direct transfer to another service provider.

20.6 Right to Object

• Users may object to the processing of their data where:
   
  • Processing is based on legitimate interests.
     
  • Data is being used for direct marketing purposes (in which case processing will cease immediately).

20.7 Rights Relating to Automated Decision-Making & Profiling

• FansClique does not engage in fully automated decision-making that produces legal or significant effects on users.
   
• If such processing is introduced, users will have the right to request human intervention and to contest the decision.

20.8 How to Submit a DSAR

• Users may exercise their rights by submitting a request via [email protected].
   
• Requests must include proof of identity to ensure the security of personal data.
   
• FansClique will acknowledge requests within 7 days and provide a full response within 30 days, unless an extension is legally permitted.
   

 

20.9 Appeals & Complaints

• Users dissatisfied with FansClique’s handling of their DSAR may escalate their complaint to:
   
  • The UK Information Commissioner’s Office (ICO) if the user is based in the UK.
     
  • The relevant Data Protection Authority in their jurisdiction.
     

20.10 No Fees for Standard Requests

• DSARs are processed free of charge.
   
• FansClique reserves the right to charge a reasonable fee or refuse requests that are manifestly unfounded, repetitive, or excessive.
   

21 – Complaints Handling & Regulatory Contact

FansClique is committed to transparency, accountability, and the fair treatment of all users. We take complaints regarding privacy, data protection, and the handling of personal data very seriously.

21.1 Submitting a Complaint to FansClique

• Users who believe their privacy rights have been violated, or who have concerns about how their personal data is being processed, may submit a complaint directly to FansClique.
   
• Complaints should be sent to:
  [email protected]
  [email protected] (for general concerns, which will be escalated internally if privacy-related).

21.2 Internal Complaint Resolution

• Upon receipt of a complaint, FansClique will:
   
  1. Acknowledge the complaint within 7 days.
      
  2. Conduct an internal investigation into the matter.
      
  3. Provide a written response, including any corrective actions taken, within 30 days.
      
• If more time is required due to complexity, we will notify the user and provide an estimated resolution timeframe.

21.3 Escalation to Supervisory Authorities

If a user is not satisfied with FansClique’s response, they have the right to escalate the complaint to the relevant data protection authority, depending on their jurisdiction:

• United Kingdom:
  Information Commissioner’s Office (ICO)
  Website: https://ico.org.uk
  Telephone: +44 (0)303 123 1113
   
• European Union (EU/EEA):
  Users may contact their local Data Protection Authority (DPA). A full list is available here: https://edpb.europa.eu/about-edpb/board/members_en.
   
• Nigeria:
  Nigeria Data Protection Commission (NDPC)
  Website: https://ndpc.gov.ng
   
• Other Jurisdictions:
  Users should contact their local privacy regulator for guidance.

21.4 Non-Retaliation Commitment

FansClique will never retaliate against users who file complaints in good faith. Complaints are handled confidentially, and outcomes are communicated respectfully and transparently.

21.5 Continuous Improvement

Complaints are logged, tracked, and reviewed periodically as part of FansClique’s compliance monitoring program.

• Trends or recurring issues identified through complaints will inform improvements in policies, security practices, and user communications.
   
• This ensures that FansClique continuously aligns with evolving privacy expectations and legal requirements.

22 – Updates to This Privacy Policy

FansClique reserves the right to amend, update, or revise this Privacy Policy at any time to reflect:

• Changes in applicable laws and regulations.
   
• Updates to our business practices, platform features, or technology.
   
• Feedback from users, regulators, or stakeholders.

22.1 Notification of Changes

When material changes are made, FansClique will:

• Post a clear notice on the platform (homepage, privacy center, or user dashboard).
   
• Send direct communication (email or in-app notification) to registered users where required.
   
• Indicate the “Last Updated” date at the top of the Privacy Policy.

22.2 Effective Date

• Updates become effective immediately upon posting unless otherwise specified.
   
• Continued use of FansClique services after updates are posted constitutes acceptance of the revised Privacy Policy.

22.3 User Rights During Updates

• Where updates significantly alter how FansClique processes personal data, users may be asked to review and re-consent before continuing to use the platform.
   
• Users who disagree with changes have the right to discontinue use of the service and may request account deletion in line with Part 15 (Data Deletion & Retention).
   

22.4 Version Tracking

FansClique maintains archived versions of past Privacy Policies for audit and reference purposes.

• Users may request a copy of previous versions by contacting:
  [email protected]

 

Part 23 – Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy, your personal data, or FansClique’s data practices, you may contact us using the details below:

23.1 Primary Contact (Data Protection & Privacy)

Email: ? [email protected]
Subject Line: “Privacy Policy Inquiry”

 

 

23.2 General Support & User Accounts

Email: ? [email protected]
In-App Help Center: Accessible via the FansClique dashboard under “Help & Support.”

23.3 Legal & Compliance

Email: ? [email protected]
Postal Correspondence (UK Office):
Meritearn Limited
61 Bridge Street, Kingston, HR5 3DJ,

United Kingdom

23.4 Data Protection Officer (DPO)

FansClique appoints a Data Protection Officer (DPO) responsible for overseeing compliance with data protection regulations (including GDPR and NDPR).

• Requests may be directed to: [email protected]

23.5 Escalation & Complaints

If you are unsatisfied with how FansClique handles your personal data, you may escalate complaints to the relevant Data Protection Authority in your jurisdiction, including but not limited to:

• ICO (UK Information Commissioner’s Office) – for users in the United Kingdom.
   
• NDPC (Nigeria Data Protection Commission) – for users in Nigeria.
   
• The relevant supervisory authority in your country of residence within the EEA or other applicable jurisdictions.
   

 

- Email: [email protected]