Privacy Policy

By using FansGlow, you acknowledge that you have read and understood the information in this Policy.

1. Introduction

Only fans International Limited ("we", "us", "our") respects your privacy and is committed to protecting the personal data we process about you. Only fans International Limited owns and operates fansglow.com ("FansGlow"), a social network and content-sharing platform that enables: (i) "Creators" to share and monetise their own content (and to subscribe to and view the content of other Creators); and (ii) "Fans" to subscribe to and view the content of Creators.

This privacy policy ("Policy") explains how we handle the personal data of our Creators and Fans. It also covers our practices for the personal data of individuals who appear in content uploaded by a Creator ("Content Collaborators"), and of the people we deal with while running our business.

We process your personal data whenever you use FansGlow and whenever we provide the services offered through it (the "Services"). For that processing we act as a "data controller" — meaning we decide why and how your personal data is processed. If you have questions about this Policy or how we use your personal data, see the contact section at the end for how to reach us.

2. What is personal data?

"Personal data" means information that identifies, relates to, describes or can reasonably be linked, directly or indirectly, to a particular person or household.

Information that cannot identify you — for example data that has been de-identified, aggregated or anonymised — is not personal data, and this Policy does not apply to it.

3. Informing us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your details change during your relationship with us — you can update most information through your account settings on FansGlow, or by contacting us.

4. Applicability of this Policy (18+)

This Policy supplements, but does not form part of, our Terms of Service, which govern your use of FansGlow and the Services.

Our Services are strictly intended for individuals 18 years of age or older. Anyone under 18 is not permitted to use the Services. By using the Services, you represent that you are 18 years of age or older.

5. Third-party links

FansGlow may include links to third-party websites, plug-ins and applications. Clicking those links or enabling those connections may allow third parties to collect or share data about you.

We are not responsible for, and this Policy does not apply to, the content, security or privacy practices of those other websites, plug-ins or applications. We encourage you to review the privacy and cookie policies of every third-party site you visit.

6. If you do not wish to provide personal data

We need to collect certain personal data from you to provide access to the Services, or to specific features and functionalities, in accordance with our contract with you (our Terms of Service). We are also required by law to process certain personal data about you.

If you choose not to provide personal data when we request it, we may not be able to give you access to the Services or to specific features and functionalities.

7. Updates to this Policy

We may update this Policy from time to time, and any updates take effect once the revised Policy is posted on FansGlow. We will use reasonable efforts to notify you of material updates — for example by sending a feed notification or a chat message via your account.

8. Categories of personal data

We process, or our third-party providers process on our behalf, different kinds of personal data about Creators, Content Collaborators and Fans, grouped as follows. Items marked with * are requested from Content Collaborators where a release form is required.

• User Data. For Creators and Content Collaborators: full name*, alias if applicable, residential address, city and country of birth, country of residence*, email address, telephone number, a copy of the government identity document you provide*, a "selfie" of you holding that document*, third-party social media handle or personal website address, and your signature on release forms if you feature in a Creator's content*. For Fans: email address and telephone number.
• Third-Party Onboarding Data. Collected directly by our third-party providers during onboarding — for Creators and Content Collaborators, and for Fans where we conduct age or identity verification: a copy of the government identity document you provide to our providers, a short clip taken from a "selfie" capture, the result of the verification or age estimation process (pass / fail and reason), and associated metadata such as start and finish time. This data does not include Face Recognition Data, as explained below.
• Account Data. For Creators: profile name, password, avatars and headers, your subscriptions, subscribers and referrals, your posts and comments, chat messages between you and other users, and customer support queries. For Fans: profile name, password, avatars and headers, your subscriptions, comments, chat messages, and customer support queries.
• Financial Data. For Creators: payment card details*, billing address, wallet funds, bank account information, pay-out country, corporate or business entity details, VAT number, tax identification number and issuing country, and (for US Creators only) W-9, 1099-MISC and 1099-NEC forms. For Fans: payment card details*, billing address and wallet funds. * Any payments to view Creator content are processed by our third-party payment providers. We do not receive your full card number, security code or expiry date; instead, the provider supplies us with a "token" representing your account, together with the card type and the first six and last four digits of the card number.
• Transaction Data. For Creators: earnings, pay-out requests, payments made to and from your Creator account, and any failed payments. For Fans: payments made to Creators and any failed payments.
• Technical Data. For Creators and Fans: internet or other electronic network activity information, including IP address (and country code) and user agent.
• Usage Data. We use cookies where necessary to let you browse the Services and reach certain pages. With your consent, we also use non-essential cookies — for example to recognise referring users and referred Creators under our referral programme. More information is in our Cookie Notice. We do not use cross-site tracking technologies, and we do not sell personal data or share it for behavioural advertising.
• Face Recognition Data. During onboarding our third-party providers may use face recognition technology to verify you digitally. Face Recognition Data is collected by, and remains with, our third-party provider. We do not ourselves collect, receive, process or hold any Face Recognition Data.
• Background Screening Data. We reserve the right to act on content or accounts where an individual has been convicted of a serious criminal offence. To enforce our Terms of Service, we may search for publicly available adverse-media information about you, and, if you are located in the U.S., use background screening providers (using your full name and date of birth) to check for a serious criminal conviction, including whether you appear on a sex offenders registry.

9. Our onboarding processes

Creators. We have processes intended to ensure that Creators are at least 18 years of age and verified as to identity. Before you can open a Creator account, we will ask you to provide the Creator User Data above, check your country of residence (the Services are not available everywhere), ask you to complete the third-party age and identity verification described below, check that you have not previously been banned, and collect the Financial Data needed to pay out your earnings.

Content Collaborators. We have processes intended to ensure that individuals featured in a Creator's content are at least 18 years of age and verified as to identity. Before you can appear in a Creator's content, you must complete the same third-party age and identity verification as Creators, and you may also be required to provide a signed release form.

Fans. We have processes intended to ensure that all Fans are at least 18 years of age, and that Fans in certain circumstances or locations verify their identity. Before you can start a Fan account, we will ask you to provide the Fan User Data above, ask you (where required by law or appropriate to protect our users) to go through a third-party age estimation or age and identity verification process, and check that you have not previously been banned.

Third-party age and identity verification. We use third-party providers to conduct age and identity verification. The process involves the provider collecting a short clip taken from a "selfie" and a photo of the government identity document you provide, then using facial matching technology to verify your age and identity digitally. We do not collect, receive, process or have access to any Face Recognition Data used in this process. Where permitted by law, we receive the Third-Party Onboarding Data above to keep a record of the process.

Third-party age estimation. For certain locations we use third-party providers to estimate the age of Fans, which can be done in different ways depending on your location and the law. Email-address age estimation uses your email address to estimate whether you are under or over 18; it does not identify you and we receive only the result. Where email-address estimation is not permitted or returns no clear result, you may be asked to undergo facial age estimation, which involves providing the provider a short "selfie" clip and using digital technology to estimate your age; it is not used to recognise you and does not involve Face Recognition Data being retained by us. If you fail age estimation, you may be offered the full age and identity verification process instead.

More information. Face recognition technology used by our providers is an important measure in our wider onboarding processes, intended to keep FansGlow safe and secure and to support our compliance with applicable laws. It reduces face-image spoofing and fraudulent identity documents by allowing a live capture to be compared against the document provided. During the time you hold an account, we may require you to periodically re-authenticate your identity; where permitted by law, our providers may retain Face Recognition Data so that you can do this quickly without re-submitting your document and a new "selfie" each time. You may withdraw your consent to that retention (and request deletion) by contacting [email protected]; this will not affect your access to the Services, but you will need to repeat verification the next time authentication is required.

10. How and why your personal data is used, and lawful bases for processing

We process personal data only where we have a lawful basis to do so. We rely on one or more of the following:

• Consent: requested only in specific circumstances, including the processing of Face Recognition Data by our providers during age and identity verification, and age estimation captures by our providers for Fans in certain locations.
• Performance of a contract: by using the Services you contract with us through our Terms of Service, and we process personal data to perform that contract (for example to fulfil transactions between Fans and Creators and process Creator earnings) and to enforce it.
• Legitimate interests: where processing is in our or a third party's legitimate interests — for example investigating and responding to a report made through our DMCA takedown procedure to help protect a Creator's intellectual property.
• Compliance with legal obligations: to comply with applicable laws, rules and regulations in the locations where we operate, such as financial and tax reporting requirements.
• Task carried out in the public interest: for example reporting illegal activity to relevant law enforcement and other authorities, non-governmental organisations and industry peers.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another, compatible reason. The processing purposes we rely on include: creating Creator and Fan accounts; age and identity verification and subsequent authentication; age estimation; checking the validity of government identity documents; providing the Services, including hosting Creator content, fulfilling transactions and processing earnings; identifying referring and referred users under our referral programme; providing technical support; communicating with you about the Services and policy updates; enforcing our Terms of Service and Acceptable Use Policy, including background checks where applicable; moderating and filtering content, livestreams and messages; removing illegal or violating content and suspending accounts; maintaining a record of banned users; reporting illegal activity and responding to lawful requests; preserving and sharing data in legal proceedings; monitoring our systems to detect fraud and protect information security; protecting the rights and property of our users, ourselves and third parties; system maintenance, testing and improvement; and dealing with a possible sale, merger, acquisition or restructuring. Some grounds overlap, and more than one may justify the same processing.

11. Obtaining your personal data

We collect your personal data from the following sources:

• Directly from you: when you provide it to open an account and use the Services, update your account, or correspond with us, including when you interact with us through our social media pages.
• Automatically or indirectly from you: through your use of the Services (for example Transaction, Technical and Usage Data), if you sign in via a third-party single sign-on, or if you connect a third-party account to your FansGlow account.
• From our service providers: for example, where permitted by law, we receive Third-Party Onboarding Data and certain Technical Data from our age and identity verification providers.

12. Sharing your personal data

We share personal data with the following categories of third parties:

• Our third-party service providers: such as our IT, payment processing, customer support, content and text moderation, tax automation, background screening, and age and identity verification providers. They act on our behalf and may use personal data only for the purposes we instruct. We rely on our legitimate interests in receiving the services that keep our business running.
• Our professional advisers: such as our legal advisers, bankers, auditors, accountants, consultants and insurers, who provide banking, legal, consulting, accounting, insurance and similar services. We rely on our legitimate interests in obtaining the advice needed to operate our business.
• Corporate parties: relevant third parties in a possible sale, merger, acquisition, reorganisation or restructuring, relying on our legitimate interests in the orderly transfer or continuation of our business where your rights do not override those interests.
• Group companies: for the centralised coordination and management of our business, in line with the purposes above.
• Relevant authorities, regulators and organisations: including law enforcement, other governmental and tax authorities, industry peers and recognised non-governmental organisations such as the National Center for Missing & Exploited Children (NCMEC), where required or permitted by law.

13. International data transfers

We share your personal data within our group of companies and with the third parties described above, which may involve transferring it outside the UK, the EEA and Switzerland, and in some cases outside your jurisdiction. We make those transfers to countries deemed to provide an adequate level of protection, using appropriate safeguards such as standard contractual clauses, or where otherwise authorised by law. Please contact us if you would like further information on the specific mechanism used.

14. Your rights regarding personal data

You have certain rights regarding the collection and processing of your personal data, which you may exercise by contacting us using the details below. Under certain circumstances, and subject to certain exemptions, you have the right to:

• withdraw your consent to processing (this does not affect the lawfulness of processing carried out before withdrawal);
• request to know or access the personal data we hold about you and check that we are processing it lawfully;
• request correction of incomplete or inaccurate personal data;
• request deletion or erasure where there is no legitimate reason for us to continue processing it — we may refuse for specific legal reasons, for example where your account was deactivated for violating our Terms of Service;
• request restriction of processing, for example while we establish its accuracy or the reason for it;
• request transfer of some elements of your personal data to another party;
• lodge a complaint with a data protection regulator (in the UK, the Information Commissioner's Office; in Switzerland, the FDPIC; in the EEA, your country's data protection authority); and
• appeal a decision we have made about your privacy request, depending on the U.S. state in which you are located (see the U.S. state disclosures below).

You also have the right to object to processing where we rely on a legitimate interest and there is something about your particular situation that makes you want to object. We do not process personal data in a way that consists of solely automated decision-making where the decision has a legal or similarly significant effect on you.

15. Exercising your rights

To exercise the rights above, contact us using the details below. Please make sure your request contains enough information for us to confirm your identity and to understand, evaluate and respond to it; we may need to request additional personal data to verify your identity, and we may decline requests we cannot verify. If your request is made by an authorised third party, we will also require proof of authorisation and may still verify your identity directly with you. You will not normally have to pay a fee, and we will respond within the timeframes required by law.

16. Choices and control over your personal data

• Modifying and deleting your personal data. If you have an account, you may update certain personal data through your account settings; changes may take some time to take effect.
• Device permissions. You can use your device settings to control which permissions (such as camera or photo access) are granted to FansGlow.
• Email notifications. You may opt out of non-essential email notifications through your notification preferences, or by emailing [email protected] with "Email notification opt-out" in the subject line. Certain automated notifications — such as account verification, transactional and security messages — are necessary to provide the Services and cannot be disabled.

17. Retention of personal data

We retain your personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, decided case by case according to the circumstances. In general:

• Providing our Services: where we need personal data to provide the Services or perform our contract with you, we keep it for as long as you hold an account with us.
• Trust and safety: if you have (or we reasonably suspect you have) violated our Terms of Service, or where we otherwise need to identify and report illegal activity or protect our users, we retain certain personal data for as long as necessary to conduct investigations, assist authorities (such as NCMEC), and enforce any permanent account closure.
• Compliance with laws: we retain personal data to satisfy legal, accounting or reporting requirements — for example financial and identity records may be kept for up to 7 years after you stop being a user, or longer where we receive a valid legal preservation request.
• Legal claims: we retain personal data in line with applicable limitation periods, and longer where needed in connection with actual or threatened legal proceedings.

18. Additional U.S. state privacy disclosures

Where required by law, these additional U.S. state privacy disclosures supplement this Policy with further information about our processing practices relating to residents of certain U.S. states. Unless otherwise stated, all terms keep the same meaning here. For these disclosures, personal data does not include publicly available information or de-identified, aggregated or anonymised information maintained in a form that cannot be associated with or linked to you.

No sales or targeted advertising. We do not sell or share personal data to display advertisements selected based on personal data obtained or inferred over time from your activities across different businesses or services (known as "targeted advertising").

Sensitive information. Although sensitive information may be one of our service providers' data categories, we do not sell or share it for targeted advertising. Elements that may be classified as "sensitive" under certain privacy laws include usernames and passwords; social security, driver's licence and passport numbers; government identifiers; partial payment card numbers and the name registered with your card; and Face Recognition Data (biometric information collected and processed by our third-party providers). We use this information only as set out in the lawful-bases section, to the extent necessary to operate the Services, perform a contract with you, comply with legal requirements, protect the safety of our users and third parties, or as otherwise permitted by law.

De-identified information. We may receive, or process personal data to create, de-identified information that can no longer reasonably be linked to a particular individual or household. Where we maintain such information, we keep and use it in de-identified form and will not attempt to re-identify it except as required or permitted by law.

Appeals. If you are a resident of certain U.S. states, you may appeal decisions about your privacy requests using the contact details below. If your appeal is denied, you may contact your state Attorney General to submit a complaint.

California-specific disclosures. The following apply only to California residents. California law requires us to describe the personal data we collect by reference to statutory categories. The categories we collect map to: Identifiers (name, alias, address, phone, email, government identity information, account information); Customer Records (name, signature, address, passport number, partial card information, bank or other financial information); Protected Classification Characteristics (age, date of birth, gender); Commercial Information (products or services purchased and your use of the Services); Biometric Information (limited to Face Recognition Data, which remains with our providers); Internet / Network Information (device, log and analytics data); Sensory Information (pictures and videos you upload); Professional / Employment Information (any business you are associated with and your role); Other Personal Data (communication preferences and history, social media interactions, and messages and their metadata); and Inferences (information generated from your use of the Services). We may disclose all of these categories for a business purpose to service providers or other third parties as described in this Policy, including our group and affiliated companies, service providers, professional advisers, corporate parties, and relevant authorities and organisations. We collect personal data directly from you, from your browser or device, and from our business partners, affiliates and other providers, for the purposes described above. We may also offer financial incentives in connection with our referral programme; participation is optional, the material terms are provided at sign-up, you may withdraw at any time, and we have determined that the value of any referral payment is reasonably related to the value of the personal data we process for it.

Nevada-specific disclosures. Nevada law requires operators of online services to let Nevada residents opt out of the sale of personal data. Although we do not sell personal data, Nevada residents may still submit such an opt-out request using the contact details below.

19. Assistance and contact information

We have appointed a Data Protection Officer who, together with our team, oversees questions, requests and concerns about this Policy and our processing of your personal data. If you have any questions, please submit a ticket through your account or contact us at:

[email protected]
Only fans International Limited, company number 00000000
9th Floor, 1 Example Street, London, England and Wales

We have also appointed a representative for users located in the EU, who can be reached through the contact details above — please mark your message for the attention of our EU representative.