privacy policy

01 Dec, 2025

By using theFANBANK, you agree that you’ve read and understand this Policy.

1. Summary

2. Definition of Personal Data

3. Notifying Us of Updates

4. Who This Policy Is For (18+)

5. Links to Third-Party Websites

6. If You Don’t Share Your Personal Data

7. Keeping This Policy Up to Date

8. Types of Personal Data

9. The way we handle onboarding

10. Purposes for Using Your Personal Data and Legal Grounds for Processing

11. Getting a Copy of Your Personal Data

12. Sharing Your Information

13. How We Move Your Data Internationally

14. Your Personal Data Rights

15. Making Use of Your Rights

16. Your Data, Your Choices

17. How Long Your Data Is Kept

18. State-Specific Privacy Disclosures (U.S.)

19. How to Contact Us

1. Summary

Marmont Encore Limited (“we”, “us”, “our”) is dedicated to respecting your privacy and

safeguarding the Personal Data we process about you. Marmont Encore Limited owns and

operates www.theFANBANK.com (“theFANBANK”), a social networking and content sharing

platform that allows: (i) “Creators” to share and monetise their own content, as well as

subscribe to and view content from other Creators; and (ii) “Fans” to subscribe to and view

Creators’ content.

This Privacy Policy (“Policy”) outlines our practices regarding the Personal Data processed in

relation to our Creators and Fans. It also covers our approach to Personal Data concerning

individuals featured in content uploaded by a Creator (“Content Collaborators”) and addresses

how we handle Personal Data within our business relationships.We process your Personal Data when you use theFANBANK and as part of providing the services

available through theFANBANK (the “Services”). As a “data controller,” we determine the

purposes and means of processing your Personal Data in connection with the Services.

For any questions regarding this Policy or our handling of your Personal Data, please refer to

Section 19 (assistance and contact information) to learn how to contact us.

2. Definition of Personal Data

"Personal Data" refers to information that can identify, relate to, describe, or reasonably be

associated with, or linked—directly or indirectly—to a specific individual or household.

Additionally, we may collect data that cannot identify you or is not otherwise associated or

linked with you, including deidentified, aggregated, or anonymized information. Such data does

not constitute Personal Data, and our use of it is not governed by this Policy.

3. Notifying Us of Updates

We need your Personal Data to be up-to-date and correct at all times. If anything changes,

please let us know during your time with us. You can update or fix your details directly through

your account settings on theFANBANK.

4. Who this Policy is for (18+)

This Policy supplements, but is not part of, our Terms of Use and Acceptable Use Policy.

Our Services are for users 18 or older; anyone under 18 is prohibited. By using the Services, you

confirm you are at least 18 years old.

5. Links to Third-party websites

theFANBANK may contain links to external websites, plug-ins, and applications. By clicking on

these links or enabling such connections, third parties may gain access to or collect Personal

Data about you.

Please note that we do not assume responsibility for the content, security, or privacy practices

of these external websites, plug-ins, or applications, and this Policy does not extend to them.

We recommend reviewing the privacy and cookie policies or notices provided by these third

parties to understand how your Personal Data may be processed.

6. If you don’t share your Personal Data

To give you access to our Services and specific features, we must collect certain Personal Data

as outlined in our contract with you (our Terms of Use) and as required by law. If you decide not

to provide the requested Personal Data, we may be unable to offer you access to the Services or

some of their features.

7. Keeping this Policy Up to date

This Policy may be updated periodically, with all changes becoming effective upon the posting

of the revised Policy on TheFANBANK. In the event of material updates, we will make reasonable

efforts to inform you, which may include sending a feed notification or a chat message via your

account on theFANBANK.8. Types of Personal Data

We, or our third-party providers acting on our behalf, process different types of Personal Data

related to Creators, Content Collaborators, and Fans. For clarity, we have grouped this data into

the following categories:

Type of Information We Collect Description

User Information Content Creators & Collaborators

• full name*

• alias, if applicable

• residential address

• city of birth

• country of birth

• country of residence*

• email address

• telephone number

• A copy of the government-issued

identity document you submit

• a "selfie" of you holding your

government- issued identity

document

• Third-party social media handle or

personal website address (used to

verify your age and identity and to

help us better understand the type of

content you are likely to share on

theFANBANK)

• Signature on release forms if you

appear in a Creator’s content *

Please be aware that items marked with an *

indicate that Content Collaborators must

submit a release form.

Fans

• email address

• telephone number

Information Collected from Third Parties

During Onboarding

The following types of Personal Data are

collected directly by our third-party providers

as part of the onboarding process:

Creators and Content Collaborators• A copy of the government-issued

identity document you submit to our

third-party providers

• A short GIF generated from the

“selfie” you submit to our third-party

providers

• The results of the third-party age and

identity verification process

(including pass/fail status and, if

applicable, the reason for failure)

• Information about the third-party age

and identity check, such as when it

started and ended

Fans

• If we use third-party services to verify

the age and identity of Fans, we may

collect a copy of the government-

issued identity document you

provide.

• If we carry out third-party age

estimation or age and identity

verification, we may collect a short

GIF created from a selfie you provide.

• We collect the results of the third-

party age estimation or verification

process, including whether you

passed or failed and, if applicable,

the reason for failure.

• We collect metadata from the third-

party process, such as when the

verification started and finished.

For more information, see Section 9 (Our

Onboarding Processes).

Please note: Third-Party Onboarding Data

and Technical Data do not include Face

Recognition Data, as described below.

User Account Details Creators

• Profile name

• Password

• Avatars and header images of your

Creator account

• Your subscriptions, subscribers, and

referrals

• Posts you have made on your Creator

account

• Comments on posts from your

Creator account

• Chat messages between you and

other users• Customer support requests you

submit to us

Fans

• profile name

• password

• avatars and headers of your Fan

account

• your subscriptions

• comments on posts made from your

Fan account

• chat messages between you and

other users

• customer support queries that you

submit to us

Financial and Billing Data Creators

• Payment card details*

• Billing address

• Funds added to your wallet

• Bank account information

• Payout country

• Corporate or business entity name,

country, identification number, and

identification type

• VAT number

• Tax identification number and issuing

country

• W-9 form (for U.S. Creators only)

• 1099-MISC form (for U.S. Creators

only)

• 1099-NEC form (for U.S. Creators

only)

• Your payment card information*

• Your billing address

• Money added to your wallet

*Any payments made to access Creator

content are processed by our third-party

payment providers. We do not receive your

full payment card number, expiration date, or

security code. Instead, the payment provider

supplies us with a token representing your

account, the card type, the card’s expiration

date, and the first six and last four digits of

your payment card number.

Fans

Transaction Information Creators

• Money you earn

• Requests to withdraw funds

• Payments added to your account

• Payments sent to other Creators

• Failed payment attemptsDevice and Tech Info User Activity Data Facial Recognition Information Screening and Verification Data Fans

• Payments sent from your Fan account

to Creators

• Any failed payment attempts

Creators and Fans

Information about your internet or network

activity, such as:

• Your IP address and country

• Your browser or device type (user

agent)

Creators and Fans

We use cookies where necessary to allow

you to browse the Services and access

certain pages of TheFANBANK. With your

consent, we use non-essential cookies to

enable us to recognise Referring Users, and

Referred Creators, under the Referral

Program in our Terms of Use.

More information on our use of cookies can

be found in our Cookie Notice.

We currently do not use any cross-site

tracking technologies and we do not sell

Personal Data collected about you, or share

Personal Data collected about you for cross-

context behavioural advertising.

Creators, Content Collaborators and Fans

where applicable

• We use cookies that are necessary to

help you browse the Services and

access certain pages on

TheFANBANK. With your permission,

we also use non-essential cookies to

recognise Referring Users and

Referred Creators in the Referral

Program, as explained in our Terms of

Use.

• For more information, see our Cookie

Notice.

• We do not use cross-site tracking

technologies, and we do not sell or

share your personal data for

advertising purposes.

Creators, Content Collaborators, and Fans

(where applicable):• We reserve the right to take action on

content or accounts if an individual

has been convicted of a serious

criminal offence.

• To help enforce our Terms of Use:

o We may review publicly

available information about

you, including any adverse

media.

o If you are based in the U.S.,

we may use background

screening providers to check

for serious criminal

convictions, including

appearances on sex offender

registries. We may use your

full name and date of birth to

obtain this information.

9. The way we handle onboarding

CREATORS

TheFANBANK has procedures in place to make sure that Creators: (i) are at least 18 years old,

and (ii) have verified their identity. To set up a Creator account, you’ll need to:

• Provide your Creator User Data, as outlined in Section 8 (categories of Personal Data).

• Confirm what country you live in, so we can ensure TheFANBANK and its Services are

legally accessible.

• Share your Financial Data, also detailed in Section 8 (categories of Personal Data). This

allows us to process payments to Creators and lets you access your earnings on

TheFANBANK. We also use this information for verification and to prevent fraud.

• Complete an age and identity check through a third-party service, as explained below.

• Make sure you haven’t been banned from TheFANBANK or our Services before (such as

for violating our Terms of Use).

CONTENT COLLABORATORS

TheFANBANK requires Content Collaborators to verify they are at least 18 years old and confirm

their identity through a third-party process before appearing in any Creator content. A release

form may also be needed.

FANS

We have established procedures to ensure that: (i) all Fans on TheFANBANK are at least 18

years of age; and (ii) under certain circumstances or locations, Fans are required to verify their

identity. Prior to creating a Fan account, we will:

• Request Fan User Data, as outlined in Section 8 (categories of Personal Data).• Verify your country of residence to ensure lawful access to TheFANBANK and its

Services.

• Request Financial Data, also detailed in Section 8 (categories of Personal Data), which is

necessary for facilitating payments to Creators and serves as part of our verification and

anti-fraud protocols.

• Require you to complete an additional third-party process for further confirmation of

your age. This may involve third-party age and identity verification, or age estimation

processes, as described below. The specific procedure implemented will be determined

by your location or other relevant factors, such as detection of suspicious activity on

your account.

THIRD-PARTY AGE AND IDENTITY VERIFICATION

We use third-party providers to verify age and identity. They collect a short .gif from your "selfie"

and a photo of your government ID (both provided by you). Using Face Recognition Data, they

match the images to confirm your age and identity.

As noted in Section 8 (categories of Personal Data), we do not access or control any Face

Recognition Data handled by these providers. Where allowed by law, we receive Third-Party

Onboarding Data from them as described in Section 8 to keep records of the verification

process.

THIRD-PARTY AGE ESTIMATION

In some places, we use outside companies to estimate users' ages. The method of age

estimation varies by location and local laws.

Email Address Age Estimation: We might work with a third party to check if you are over or under

18 by using your email address. This means they look at websites and apps where you've used

this email before.

Facial Age Estimation: If email-based age estimation doesn't work or isn't allowed where you

are, you might be asked to try Facial Age Estimation instead. In this case, our provider collects a

brief .gif "selfie" that you upload, then uses technology to estimate your age. This process does

not identify you and does not use Face Recognition Data.

As mentioned in Section 8 (categories of Personal Data), we don't collect, receive, or access any

Face Recognition Data handled by our third-party providers during this process.

If you go through age estimation with a third party, we only get the results (whether you passed

or failed, and why) so we can keep a record of what happened.

If you fail this age estimation (for example, you are actually over 18 but the technology predicts

otherwise), you might have the option to try another third-party process for age and identity

verification as described earlier.

MORE INFORMATION ON OUR ONBOARDING PROCESSES

Why does theFANBANK use third-party face recognition technology?

Third-party face recognition helps ensure safety, security, and legal compliance on theFANBANK

. These providers verify age and identity as data processors for us.

How does Face Recognition Data help to prevent fraud?Face recognition lowers the risk of fake images and fraudulent documents during onboarding.

Records of suspected fraud, including Face Recognition Data, may be kept to detect and

prevent unlawful activity.

Periodic authentication of your age and identity

We may ask you to periodically confirm your identity. If permitted by law, our providers may

retain Face Recognition Data so you don't have to submit your ID again.

Withdrawing your consent: To withdraw consent to retaining Face Recognition Data for future

authentication, email privacy@theFANBANK.com. Withdrawal means you might need to provide

your ID again for authentication, but your access is not affected.

10. Purposes for Using Your Personal Data and Legal Grounds for Processing

We process Personal Data in accordance with one or more of the following legal bases:

Consent: Consent is obtained only when required, such as for the processing of: (i) Face

Recognition Data by third-party providers during age and identity verification for all Creators

(and, in certain circumstances or locations, for Fans); and (ii) age estimation captures (which

may involve Face Recognition Data) by third-party providers for Fans in designated locations.

Additional details can be found in Section 9 (our onboarding processes).

Carrying out our agreement with you: By utilizing our Services, you enter into an agreement with

us under our Terms of Use. We process Personal Data to fulfill this contract, including

facilitating transactions between Fans and Creators, processing Creator earnings, and enforcing

contractual terms.

Activities necessary for our business operations: Personal Data may be processed when

necessary to pursue Activities necessary for our business operations of our company or third

parties, as outlined in the table below. For example, we may investigate and respond to reports

submitted through our DMCA takedown procedure in order to protect the intellectual property

rights of Creators.

Meeting our legal responsibilities: Processing of Personal Data may occur to ensure compliance

with applicable laws, regulations, and rules in the jurisdictions where we operate, such as

financial and tax reporting requirements.

Task carried out in the public interest: We may process Personal Data when required for actions

undertaken in the public interest, including reporting illegal activity to appropriate law

enforcement agencies, government authorities, non-governmental organizations, and industry

partners.

Personal Data will only be used for its originally intended purposes unless there is a reasonable

need to use it for another purpose that aligns with the original intent.

The table below provides further detail regarding the specific purposes for which your Personal

Data is processed and the corresponding legal justification(s). Some processing activities may

be supported by multiple legal bases.

Processing:Why We Use Your Data Account creation for both Creators and Fans

Age and identity verification and, where

applicable, subsequent authentication

(specifically relating to the processing of

Face Recognition Data)

For more details, please refer to Section 9

(Our Onboarding Processes).

Facial Age Estimation (in certain locations,

specifically for processing the age estimation

capture).

For more information, see Section 9 (Our

Onboarding Processes).

Estimating Age Using Your Email Address Checking your ID and keeping a record of age

and identity verification

Keeping track of age checks for Fans in

certain locations

Providing the Services, such as hosting

Creator content, handling payments between

Fans and Creators, and managing Creator

earnings

Identifying users who refer others and those

who are referred, according to our Referral

Program Terms

Helping Fans and Creators with technical

issues

Contacting you about the Services,

answering your support questions, and

sharing updates or important information

Ensuring compliance with and enforcing our

Terms of Use and other usage policies (e.g.,

our Acceptable Use Policy). As described in

Section 8 (Categories of Personal Data), this

may include checking whether you have a

serious criminal conviction, including

appearances on sex offender registries.

A simpler, user-friendly version could be:

• Making sure users follow our Terms of

Use and other rules (like the

Acceptable Use Policy). This may

include checking for serious criminal

convictions, including listings on sex

offender registries.

• Managing and Filtering Content Grounds for Processing Personal Data

Carrying out our agreement with you

Permission

Carrying out our agreement with you

Carrying out our agreement with you

Carrying out our agreement with you

Carrying out our agreement with you

Permission

For more information, please refer to our

Cookie Notice..

Carrying out our agreement with you

Carrying out our agreement with you

Carrying out our agreement with you

Important public interest for the detection

and prevention of illegal acts)

Carrying out our agreement with you• Anything you upload, including text

and other content on theFANBANK

• livestreaming on the FANBANK

• Anything you send in chat messages

on theFANBANK

To check for and look into any breaches of

our Terms of Use

Checking messages you send on

TheFANBANK to investigate possible

breaches of our Terms of Use

Deleting illegal content uploaded by users

and suspending or closing their accounts

Removing user-uploaded text and content

that violates our Terms of Use, and, when

appropriate, suspending or deactivating the

associated user accounts.

Tracking banned users to stop them from

using theFANBANK

Informing the appropriate authorities and

organisations about illegal activity

Providing relevant information to, or

responding to requests from, law

enforcement authorities, other governmental

authorities, non-governmental organisations,

and industry partners.

Keeping and sharing personal data when

required for legal cases

Complying with all applicable laws, rules,

and regulations.

Monitoring transactions and our systems to

spot fraud or illegal activity, protect security,

and investigate incidents when needed

When needed to protect the rights and

property of our users, us, or others

Maintaining and testing systems, hosting

data, and reporting to keep the Services safe,

functional, and performing well

When needed for a possible sale, merger, or

business restructuring

Using personal data for sponsorships and

business relationships, like with service

providers or advisers, including contact info

and correspondence

11. Getting a Copy of Your Personal Data

Carrying out our agreement with you

Meeting our legal responsibilities

Carrying out our agreement with you

Carrying out our agreement with you

Tasks needed to operate our business

Meeting our legal responsibilities

Tasks needed to operate our business

Action undertaken for public benefit

Meeting our legal responsibilities

Tasks needed to operate our business

Action undertaken for public benefit

Tasks needed to operate our business

Meeting our legal responsibilities

Tasks needed to operate our business

Tasks needed to operate our business

Important public interest for the detection

and prevention of illegal acts

Tasks needed to operate our business

Tasks needed to operate our business

Tasks needed to operate our business

Carrying out our agreement with you

Tasks needed to operate our business• We receive your Personal Data from several sources:

• Directly from you: This includes when you provide details to open an account or use our

Services, update your information, or communicate with us (such as User Data or

Account Data). We may also process your data when you engage with our social media

profiles on third-party platforms.

• Automatically or indirectly from you: For instance, we collect data through your use of

our Services (including Transaction Data, Technical Data, and Usage Data), when you

sign in to TheFANBANK using a third-party single sign-on, or when you link another

account to your TheFANBANK account.

• From our service providers: When allowed by law, we may obtain Third-Party Onboarding

Data and certain Technical Data from third-party age and identity verification providers.

12. Sharing Your Information

• We share your personal data with several types of third parties:

• Third-party service providers: These include companies that help us with IT services,

payment processing, customer support, content moderation, tax automation,

background checks, and age or identity verification. We share data with them because

it’s necessary for our legitimate business needs.

• Professional advisers: This group covers our legal advisers, bankers, auditors,

accountants, consultants, and insurers. They use your personal data only as required to

provide their services, and sharing is based on our need for professional support.

• Corporate transactions: If there is a possible sale, merger, acquisition, reorganisation, or

restructuring, we may share data with relevant third parties. We do this to assess and

manage these potential business activities.

• Group companies: We may share personal data within our company group for the central

management and coordination of our business. Group companies will handle data in line

with this policy and for the reasons stated here.

• Authorities, regulators, and organisations: We might share your personal data with

government authorities (including law enforcement and tax agencies), regulators, non-

governmental organisations (such as the National Center for Missing & Exploited

Children), and industry peers. Their use of your data depends on their roles—legal,

regulatory, charitable, or industry-related. Reasons for sharing include legal obligations,

Activities necessary for our business operations, public interest, reporting illegal activity,

assisting investigations, protecting safety, or meeting tax and financial reporting

requirements (like DAC7 in the EU).

13. How we move your Data Internationally

• We may share your Personal Data with our group companies and selected third parties,

as explained in Section 12 (sharing your Personal Data).

• Sometimes, this means your data will be sent outside the UK, EEA, and Switzerland. We

do so either to countries that have been recognized as providing sufficient protection for

Personal Data, by using proper safeguards, or when it’s allowed under relevant laws.

• If you want more details about how we transfer your Personal Data outside the UK, EEA,

or Switzerland, please contact us using the information provided in Section 19

(assistance and contact information).14. Your Personal Data Rights

• You are entitled to certain rights regarding the collection and processing of your Personal

Data. You may exercise these rights by contacting us using the details provided in

Section 19 (Assistance and Contact Information).

• Subject to applicable laws and certain exemptions, your rights include:

• Withdrawal of Consent: You may withdraw your consent to the processing of your

Personal Data at any time; however, withdrawal does not affect the lawfulness of

processing conducted before consent was withdrawn.

• Access to Personal Data: You may request access to your Personal Data, including

receiving a copy of the information we hold about you, and verify that it is being

processed lawfully.

• Correction: You may request correction of any incomplete or inaccurate Personal Data

that we retain about you.

• Erasure: You may request deletion of your Personal Data where there is no valid reason

for continued processing or where you have exercised your right to object to processing.

Please note that certain legal obligations may prevent us from fulfilling erasure requests

in specific circumstances, such as account deactivation due to violations of our Terms of

Use. For more details, see Section 17 (Retention of Personal Data).

• Restriction of Processing: You may request that we suspend processing of your Personal

Data—for example, to verify its accuracy or the basis for its processing.

• Data Portability: You may request that certain sections of your Personal Data be

transferred to another party.

• Additionally, you have the right to object to the processing of your Personal Data if the

processing is based on legitimate interest and your particular situation gives rise to valid

grounds for objection.

• We do not engage in solely automated decision-making with respect to Personal Data

where such decisions produce legal or similarly significant effects.

• You also have the following rights:

• To lodge a complaint with a data protection authority. For instance, in the UK this is the

Information Commissioner's Office (ICO), and in Switzerland, the Federal Data

Protection and Information Commissioner (FDPIC). Individuals residing in the EEA may

contact their local data protection regulator.

• Depending on your jurisdiction in the U.S., you may be entitled to protection against

retaliatory or discriminatory treatment for exercising your rights, as well as the right to

appeal decisions related to privacy requests. Further guidance on appeals can be found

in Section 18 (Additional U.S. State Privacy Disclosures).

15. Making Use of Your Rights

• To exercise the rights described in Section 14 (Your Rights Regarding Personal Data),

please contact us using the information provided in Section 19 (Assistance and Contact

Information).

• When submitting a request, ensure that you provide sufficient details to enable us to

verify your identity and appropriately assess and respond to your inquiry.• We may request additional Personal Data as needed to confirm your identity, considering

our relationship and the nature of your request. In some cases, we may be unable to fulfil

a privacy rights request if we cannot verify your identity.

• If a third party is authorised to make a request on your behalf, proof of such

authorization—such as a signed document or a valid power of attorney—will be required.

16. Your Data , Your Choices

• You can manage or remove your personal data at any time. If you have an account,

simply go to your account settings on TheFANBANK to make updates. Keep in mind that

changes may take some time to process.

• Controlling Device Information Access:

• You control what technical data the Services can access through your device’s "Settings"

app. For example, you can turn off permissions for accessing network devices or your

location.

• Email Notification Preferences:

• We don’t send direct marketing emails, but you will receive notifications about important

account activities (like new subscribers, tips, or subscription renewals for Creators). To

opt out of certain types of emails, update your notification preferences on TheFANBANK

or contact us using the details in Section 19 (assistance and contact information). If

emailing, include "E-mail notification opt-out" as the subject and provide your name and

account email address.

• Please note: Some automated emails—such as those for account verification,

transactions, feature updates, or security notices—are required for service delivery or

legal compliance, so you can’t opt out of these.

17. How Long is Your Data Kept?

• We retain your Personal Data only as long as needed for the purposes described in this

Policy. Retention periods vary depending on specific circumstances:

• Providing Services: We keep Personal Data for the life of your account or as long as

necessary to deliver relevant services or features.

• Trust and Safety: If there is a violation or suspected violation of our Terms of Use, or if we

need to address illegal activities or protect users, certain data may be kept as long as

needed for investigations and enforcement.

• Legal and Regulatory Compliance: We retain data as required by law, such as identity or

financial record keeping (up to 7 years) and in response to valid legal requests or

regulatory processes. Data is deleted sooner if laws require it.

• Legal Claims: Data is held according to applicable limitation periods, and longer if

needed for litigation or complaints.

18. State Specific Privacy Disclosures (USA)

• These U.S. Disclosures provide extra information about our Personal Data practices for

residents of certain U.S. States, as required by law. Terms used here follow definitions

from the main Policy. For these disclosures, Personal Data excludes publicly available,

deidentified, aggregated, or anonymized data that cannot be linked to you.

• No sales for targeted advertising• We do not sell or share Personal Data for targeted advertising based on information

collected or inferred over time from individuals’ activities across different businesses,

websites, apps, or services.

• Sensitive Information

• While sensitive information might be disclosed for certain business purposes, we do not

sell or share this data for targeted advertising.

• We or our service providers may collect personal data considered "sensitive" under

some privacy laws, including:

• usernames and passwords,

• social security numbers, driver's license numbers, and passport numbers,

• other government-issued IDs (like driver’s licenses),

• partial payment card numbers along with the name on your card, and

• face recognition data (biometric details collected and processed by our third-party

partners).

• We use this sensitive information as detailed in Section 10 (how and why your Personal

Data is used and lawful bases for processing)—to operate our Services, fulfill

contractual obligations, meet legal requirements, protect user safety, and for other

lawful internal purposes.

• Deidentified Information

• We may process Personal Data to create deidentified information that cannot be linked

to an individual or household. We will keep such information deidentified and will not

attempt to reidentify it unless required by law.

• Appeals

• Residents of certain U.S. States can appeal privacy decisions using the contact details in

Section 19. If an appeal is denied, you may contact your local Attorney General.

• Minors

• Our Services are for users 18 years or older. By using the Services, you confirm you are at

least 18 years old.

Disclosures Required Under California Law

These disclosures apply only to California residents:Personal Data Collection

California law requires us to specify the categories of Personal Data we collect. The relevant

categories are listed in Section 8 (Categories of Personal Data).

• Identifiers: Your name, address, phone number, email address, passport or other

government-issued ID (including driver’s license), account information, or similar

identifiers.

• Customer Records: Driver’s license number, passport number, partial debit or credit

card information, bank account details, or other payment/financial information.

• Protected Classification Characteristics: Age, date of birth, and gender.

• Commercial Information: Details about products or services purchased and your use of

our Services.

• Biometric Information: Limited to Face Recognition Data used by third-party providers for

age and identity verification. Face Recognition Data remains with third-party providers;

we do not collect, receive, or access this data ourselves.

• Internet / Network Information: Device information and log data.• Sensory Information: Pictures and videos (content) you upload to TheFANBANK.

• Professional / Employment Information: Business or organisation you are associated

with, your title (if applicable), and information relating to your role with that business or

organisation.

• Other Personal Data: Communication preferences, customer service and

communication history, personal data you allow us to see on social media, data you

provide in questions or requests, and messages you send through our Services or make

available on social media.

• Inferences: Information generated from your use of our Services.

We may share your personal data with service providers or other third parties to help run our

business, provide the Services, or comply with the law. This can include:

• Our affiliated companies

• Service providers

• Advisers and business partners

• Other companies needed to deliver our Services

• Third parties you’ve consented to, or when required for legal reasons or business

transactions

We collect personal data from:

• You directly

• Your browser or device when you use our Services

• Our partners and affiliates

• Third parties you allow to share information with us

• Other service providers

Why We Collect Your Personal Data

We collect personal data for the reasons explained in Section 10, which covers how we use your

data and the legal basis for doing so.

About Financial Incentives

We do not use cross-site tracking, sell your personal data, or share it for advertising across

different websites. We also do not send marketing emails at this time.

We offer a Referral Program where current Creators can share a unique referral code to invite

new Creators. Referring Creators can earn payments based on the referred Creator’s earnings.The program follows our Terms of Use, and payments are calculated as described in the Referral

Program Terms.

Any Personal Data of referring or referred Creators is handled according to this Policy.

We estimate the value of Personal Data used in the Referral Program based on the costs of

collecting and processing it and running the program.

You can manage your Personal Data or exercise your rights by submitting a ticket through your

account or emailing privacy@theFANBANK.com.

Disclosures required under Nevada Law

Nevada Residents

Nevada law gives residents the right to request that their Personal Data not be sold. We do not

sell Personal Data, but Nevada residents can still submit an opt-out request using the contact

information below.

19. How to Contact Us

Our Data Protection Officer (DPO) and privacy team can answer any questions about this Policy

or how we handle your Personal Data. Submit a ticket through your account or email

support@theFANBANK.com.