Embersona

Privacy Policy

Effective date: [EFFECTIVE DATE]  ·  Last updated: [EFFECTIVE DATE]

This Privacy Policy explains how [LEGAL ENTITY NAME] ("Embersona," "we," "us") collects, uses, and protects information when you use the Embersona service (the "Service"). We are the data controller for the information described here. If you have questions, contact [SUPPORT EMAIL].

1. Who this policy covers

This policy covers Creators who sign up for Embersona, and it also explains how we process the subscriber (fan) message data that flows through a Creator's connected Fanvue account so the Service can generate replies. Creators are responsible for their own relationship with, and disclosures to, their subscribers.

2. Information we collect

CategoryExamplesWhy
Account dataName, email, password (stored only as a salted hash, never in plain text)Create and secure your account
Fanvue connectionOAuth access token issued by Fanvue, your Fanvue creator IDRead messages and send replies on your behalf
Subscriber message dataIncoming and outgoing message text, media references, and basic fan identifiers within your accountGenerate relevant, in-character replies and remember context
Content you providePersona details, media catalog metadata, pricing, greetingsConfigure how the AI represents you
Usage dataLog data, timestamps, feature usage, diagnostic eventsOperate, secure, and improve the Service
Billing dataPlan, transaction records (card details are handled by our payment processor, not stored by us)Process payments

We do not ask for or store your Fanvue password, and we request only the Fanvue permissions the Service needs.

3. How we use information

We do not sell your personal information, and we do not use one Creator's data to serve another Creator.

4. Legal bases (GDPR)

Where the GDPR applies, we process data on these bases: performance of a contract (to provide the Service you signed up for), legitimate interests (to secure and improve the Service), consent (where required, e.g., certain communications), and legal obligation (e.g., record-keeping).

5. How we share information

We share information only with service providers that help us operate, under contract and only as needed:

We may also disclose information if required by law, to enforce our Terms, or to protect the rights, safety, and security of users and the public. We do not send your data to any recipient you have not authorized.

6. Data retention

We keep account and configuration data for as long as your account is active. Message context is retained only as long as needed to provide continuity, and is purged on request or on account closure. Backups and diagnostic logs are retained for a limited period and then deleted or de-identified. When you disconnect Fanvue, we stop processing new messages for that account.

7. Your rights

Depending on where you live, you may have the right to access, correct, delete, restrict, or port your personal data, to object to certain processing, and to withdraw consent. Creators can exercise these rights in-app or by emailing [SUPPORT EMAIL]. We respond within the timeframe required by applicable law.

8. Data deletion

You can request deletion of your account and associated data at any time by emailing [SUPPORT EMAIL] or using the in-app delete option. On a valid request we delete or de-identify your personal data and stored message context promptly, except where limited retention is required by law or for security. Disconnecting your Fanvue account also revokes our access token immediately.

9. Data security

We use technical and organizational measures to protect your data, including encryption in transit, hashed passwords, access tokens stored securely and never logged in plain text, and internal access limited to staff who need it. No system is perfectly secure, but we work to protect your information and to isolate each Creator's data from every other Creator's.

10. International transfers

We may process data in countries other than yours. Where required, we use appropriate safeguards (such as standard contractual clauses) for international transfers.

11. Children

The Service is strictly for adults (18+). We do not knowingly collect data from anyone under 18. If you believe a minor has provided us data, contact us and we will delete it.

12. Cookies

Our dashboard uses only the cookies necessary to keep you signed in and to operate the Service. We do not use third-party advertising cookies.

13. Changes to this policy

We may update this policy from time to time. We will post the new effective date at the top and, for material changes, notify you by a reasonable means.

14. Contact

[LEGAL ENTITY NAME]
Email: [SUPPORT EMAIL]
Address: [BUSINESS ADDRESS, optional]

Draft template. Replace every bracketed field before publishing, and have a lawyer review this document. Given adult content and personal data, a professional review is strongly recommended. This is a starting point, not legal advice.