Privacy
## Introduction:
Langerouge SASU ("we", "us", "our") respects your privacy and we are committed to protecting the Personal Data we process about you. Landerouge SASU is the owner and operator of www.ponsly.com ("Ponsly"), a social network and content-sharing platform that enables: (i) "Creators" to share and monetize their own content (as well as 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 our practices with respect to the Personal Data processed about our Creators and Fans. It also explains our practices with respect to the Personal Data processed about individuals who feature in content uploaded by a Creator ("Content Collaborators"), and where we process Personal Data in the context of our business relationships.
We process your Personal Data when you use Ponsly and for the provision of the services we offer from time to time via Ponsly (the "Services"). We are a "data controller" of the Personal Data that we process in connection with the Services. This means that we decide the reasons why we process Personal Data about you and how we do so.
If you have any questions about this Policy or our processing of your Personal Data, please see Section 19 (Assistance and Contact Information) for information about how to contact us.
## What is Personal Data?
"Personal Data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household.
In addition, we may collect data that is not capable of identifying you or is otherwise not associated or linked with you, such as de-identified, aggregated, or anonymized information. This type of data is not Personal Data, and our use of such data is not subject to this Policy.
## 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 Personal Data changes at any point during your relationship with us. Updates or corrections can be made through your account settings on Ponsly.
## Applicability of this Policy (18+)
This Policy is provided in addition to, but does not form part of, our Terms of Service (which includes our Acceptable Use Policy) that govern your use of Ponsly and the Services.
Our Services are strictly intended for individuals 18 years of age or older. Anyone under 18 years of age is not permitted to use the Services. By using the Services, you represent that you are 18 years of age or older.
## Third-party links
Ponsly may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Personal 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 view the privacy and cookie policies / notices of those third parties to find out how your Personal Data may be used.
## If you do not wish to provide Personal Data
We need to collect certain Personal Data from you to provide you with access to the Services, or specific features and functionalities of the Services, in accordance with our contract with you (i.e. our Terms of Service). We are also required to process certain Personal Data in accordance with applicable laws. Please note that if you do not wish to provide Personal Data where requested, we may not be able to provide you with access to the Services or specific features and functionalities of the Services.
## Updates to this Policy
We may update this Policy from time to time, and any updates will be effective upon our posting of the revised Policy on Ponsly. We will use reasonable efforts to notify you in the event that material updates are made to this Policy, such as sending you a feed notification or a message via your account on Ponsly.
## 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, which we have grouped together as follows:
### Category of Personal Data | Description
**User Data**
**Creators and Content 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 identity document that you provide to us*
- A "selfie" of you holding your government identity document*
- Third-party social media handle / personal website address (used to further verify your age and identity and help us better understand the content you are likely to share on Ponsly)
- Signature on release forms if you feature in a Creator's content*
*Items marked with * will be requested for Content Collaborators where you are required to provide a release form.
**Fans:**
- Email address
- Telephone number
**Third-Party Onboarding Data**
Collected directly by our third-party providers during onboarding:
**Creators and Content Collaborators:**
- A copy of the government identity document provided to third-party providers
- A short .gif, taken from a "selfie" provided to third-party providers
- The results of the third-party age and identity verification process (pass / fail and reason for failing)
- Metadata associated with the third-party age and identity verification process (e.g., start and finish time)
**Fans:**
- If applicable, a copy of the government identity document provided for third-party age and identity verification
Please see Section 9 (Our Onboarding Processes) for further information.
**Account Data**
Collected for both Creators and Fans for purposes such as account creation, subscriptions, and communication.
**Creators:**
- Profile name, password, and avatar
- Creator content, subscriptions, and interaction history
**Fans:**
- Profile name, password, and subscriptions
- Comments on posts and messages to other users
**Financial Data**
Collected to process payments and payouts, verify identities, and for tax purposes. Payment card details for both Creators and Fans are processed through third-party providers and we do not receive full card details.
Certainly! Here is the continuation of the Ponsly Privacy Policy:
---
### **Transaction Data**
Collected for both Creators and Fans to facilitate transactions, such as:
**Creators:**
- Earnings
- Payout requests
- Payments made to or from your Creator account
- Failed payments
**Fans:**
- Payments made from your Fan account to Creators
- Failed payments
### **Technical Data**
Collected for both Creators and Fans to monitor and improve the platform:
- Internet or other electronic network activity information, including:
- Internet Protocol (IP) address (and country code)
- User agent (the information your browser provides)
### **Usage Data**
Collected to understand how the platform is used by Creators and Fans:
- Cookies: Necessary cookies are used to allow you to browse the Services and access certain pages of Ponsly. Non-essential cookies are used (with your consent) to recognize Referring Users and Referred Creators under our Referral Program.
Please see our Cookie Notice for more information on the use of cookies.
### **Face Recognition Data**
For Creators, Content Collaborators, and Fans (where applicable):
As described in more detail in Section 9 (Our Onboarding Processes), during onboarding, our third-party providers may use face recognition technology to digitally verify your identity. Face Recognition Data is collected by, and remains with, our third-party provider. We do not collect, receive, possess, or have access to Face Recognition Data at any time.
---
## Our Onboarding Processes
### CREATORS
We have processes in place to ensure that Creators on Ponsly: (i) are at least 18 years of age, and (ii) verify their identity. Before you can start a Creator account, we will:
- Ask you to provide Creator User Data as set out in Section 8 (Categories of Personal Data).
- Check your country of residence to ensure lawful access to Ponsly and the Services.
- Ask you to provide Financial Data as set out in Section 8 (Categories of Personal Data) to process payments and ensure compliance with anti-fraud measures.
- Ask you to go through a third-party age and identity verification process, as described below.
- Ensure that you have not previously been banned from using Ponsly or our Services (e.g., for violating our Terms of Service).
### CONTENT COLLABORATORS
We have processes in place to ensure that Content Collaborators on Ponsly: (i) are at least 18 years of age, and (ii) verify their identity. Before you can feature in content uploaded by a Creator, you will be asked to go through a third-party age and identity verification process, and may also be required to provide a release form.
### FANS
We have processes in place to ensure that: (i) all Fans on Ponsly are at least 18 years of age, and (ii) Fans in certain circumstances or locations verify their identity. Before you can start a Fan account, we will:
- Ask you to provide Fan User Data as set out in Section 8 (Categories of Personal Data).
- Check your country of residence to ensure lawful access to Ponsly and the Services.
- Ask you to provide Financial Data as set out in Section 8 (Categories of Personal Data) to process payments and ensure compliance with anti-fraud measures.
- Ask you to go through a third-party age verification process in certain circumstances or locations.
---
## Third-Party Age and Identity Verification
We use third-party providers to conduct age and identity verification. This process involves:
- Collecting a short .gif, taken from a "selfie" and a photo from a government identity document, both provided to the third-party provider.
- The third-party provider uses Face Recognition Data to match the two images and digitally verify your age and identity.
As described in Section 8 (Categories of Personal Data), we do not collect, receive, possess, or have access to any Face Recognition Data collected or processed by our third-party providers through this process.
Where permitted by applicable law, we receive Third-Party Onboarding Data as set out in Section 8 to maintain a record of the age and identity verification process.
---
## How / Why Your Personal Data is Used and Lawful Bases for Processing
We process Personal Data for, or based on, one or more of the following legal bases:
1. **Consent**: Your consent is required in certain situations, for example, the processing of Face Recognition Data by our third-party providers as part of the age and identity verification process.
2. **Performance of a Contract**: By using the Services, you have contracted with us through our Terms of Service, and we process Personal Data to perform that contract (e.g., fulfilling transactions between Fans and Creators, processing Creator earnings).
3. **Legitimate Interests**: We may process Personal Data if it is in our legitimate interests (or a third party's legitimate interests). This may include investigating and responding to intellectual property claims or protecting user safety.
4. **Compliance with Legal Obligations**: We may process Personal Data to comply with applicable laws, rules, and regulations (e.g., financial or tax reporting requirements).
5. **Task Carried Out in the Public Interest**: We may process Personal Data as necessary for a task carried out in the public interest, such as reporting illegal activity to law enforcement.
---
## Sharing Your Personal Data
We share Personal Data with the following categories of third parties:
1. **Our Third-Party Service Providers**: These include IT, payment processing, customer support, content moderation, and age and identity verification service providers. The lawful basis for sharing Personal Data with these recipients is that it is necessary for our legitimate interests in receiving services that support business functionality.
2. **Our Professional Advisors**: This includes legal advisors, accountants, auditors, and insurers. These parties process Personal Data as necessary to provide their services to us.
3. **Corporate**: Relevant third parties in the event of a possible sale, merger, acquisition, or business reorganization. We share Personal Data when it is necessary for our and the relevant third parties' legitimate interests in assessing and executing such transactions.
4. **Relevant Authorities, Regulators, and Organizations**: We may share Personal Data with governmental authorities, regulators, and organizations for regulatory or legal reasons. The lawful basis for sharing Personal Data in these cases depends on whether the processing is necessary for compliance with legal obligations, legitimate interests, or public interest.
---
## International Data Transfers
We share your Personal Data within our group companies and with third parties as outlined in Section 12 (Sharing Your Personal Data). In some cases, this will involve transferring your data outside France, the European Economic Area (EEA), and Switzerland. We ensure that these transfers are made using appropriate safeguards, including adequacy decisions, standard contractual clauses, or other lawful mechanisms.
---
## Your Rights Regarding Personal Data
You have certain rights regarding your Personal Data, including:
1. **Withdraw Consent**: You may withdraw your consent to processing where applicable, although this will not affect the lawfulness of processing before withdrawal.
2. **Request Access**: You may request a copy of the Personal Data we hold about you.
3. **Request Correction**: You may ask for correction of any inaccurate or incomplete data.
4. **Request Deletion / Erasure**: You may request deletion of Personal Data, subject to legal exceptions.
5. **Request Restriction**: You may ask for restricted processing of your Personal Data under certain conditions.
6. **Request Transfer**: You may request that certain Personal Data be transferred to another party.
If you wish to exercise these rights, please contact us using the contact details provided in Section 19.
---
## Retention of Personal Data
We will only retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected. The retention period varies depending on the nature of the data and the legal requirements:
- **Providing Services**: We retain your Personal Data for the lifetime of your account or as necessary to provide specific features.
- **Trust and Safety**: Personal Data may be retained to investigate suspected violations of our Terms of Service or illegal activity.
- **Legal and Regulatory Compliance**: For example, certain tax or financial records may be retained for up to 7 years to comply with legal obligations.
- **Legal Claims**: Data may be retained in accordance with statutory limitation periods.
---
## Assistance and Contact Information
We have appointed a Data Protection Officer (DPO) responsible for responding to privacy-related questions, requests, and concerns. If you have questions about this Policy or our processing of your Personal Data, you may contact us via:
- Email: privacy@ponsly.com
- Address: Langerouge SASU, 231 rue Saint-Honoré, 75001 Paris, France
Langerouge SASU ("we", "us", "our") respects your privacy and we are committed to protecting the Personal Data we process about you. Landerouge SASU is the owner and operator of www.ponsly.com ("Ponsly"), a social network and content-sharing platform that enables: (i) "Creators" to share and monetize their own content (as well as 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 our practices with respect to the Personal Data processed about our Creators and Fans. It also explains our practices with respect to the Personal Data processed about individuals who feature in content uploaded by a Creator ("Content Collaborators"), and where we process Personal Data in the context of our business relationships.
We process your Personal Data when you use Ponsly and for the provision of the services we offer from time to time via Ponsly (the "Services"). We are a "data controller" of the Personal Data that we process in connection with the Services. This means that we decide the reasons why we process Personal Data about you and how we do so.
If you have any questions about this Policy or our processing of your Personal Data, please see Section 19 (Assistance and Contact Information) for information about how to contact us.
## What is Personal Data?
"Personal Data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household.
In addition, we may collect data that is not capable of identifying you or is otherwise not associated or linked with you, such as de-identified, aggregated, or anonymized information. This type of data is not Personal Data, and our use of such data is not subject to this Policy.
## 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 Personal Data changes at any point during your relationship with us. Updates or corrections can be made through your account settings on Ponsly.
## Applicability of this Policy (18+)
This Policy is provided in addition to, but does not form part of, our Terms of Service (which includes our Acceptable Use Policy) that govern your use of Ponsly and the Services.
Our Services are strictly intended for individuals 18 years of age or older. Anyone under 18 years of age is not permitted to use the Services. By using the Services, you represent that you are 18 years of age or older.
## Third-party links
Ponsly may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Personal 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 view the privacy and cookie policies / notices of those third parties to find out how your Personal Data may be used.
## If you do not wish to provide Personal Data
We need to collect certain Personal Data from you to provide you with access to the Services, or specific features and functionalities of the Services, in accordance with our contract with you (i.e. our Terms of Service). We are also required to process certain Personal Data in accordance with applicable laws. Please note that if you do not wish to provide Personal Data where requested, we may not be able to provide you with access to the Services or specific features and functionalities of the Services.
## Updates to this Policy
We may update this Policy from time to time, and any updates will be effective upon our posting of the revised Policy on Ponsly. We will use reasonable efforts to notify you in the event that material updates are made to this Policy, such as sending you a feed notification or a message via your account on Ponsly.
## 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, which we have grouped together as follows:
### Category of Personal Data | Description
**User Data**
**Creators and Content 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 identity document that you provide to us*
- A "selfie" of you holding your government identity document*
- Third-party social media handle / personal website address (used to further verify your age and identity and help us better understand the content you are likely to share on Ponsly)
- Signature on release forms if you feature in a Creator's content*
*Items marked with * will be requested for Content Collaborators where you are required to provide a release form.
**Fans:**
- Email address
- Telephone number
**Third-Party Onboarding Data**
Collected directly by our third-party providers during onboarding:
**Creators and Content Collaborators:**
- A copy of the government identity document provided to third-party providers
- A short .gif, taken from a "selfie" provided to third-party providers
- The results of the third-party age and identity verification process (pass / fail and reason for failing)
- Metadata associated with the third-party age and identity verification process (e.g., start and finish time)
**Fans:**
- If applicable, a copy of the government identity document provided for third-party age and identity verification
Please see Section 9 (Our Onboarding Processes) for further information.
**Account Data**
Collected for both Creators and Fans for purposes such as account creation, subscriptions, and communication.
**Creators:**
- Profile name, password, and avatar
- Creator content, subscriptions, and interaction history
**Fans:**
- Profile name, password, and subscriptions
- Comments on posts and messages to other users
**Financial Data**
Collected to process payments and payouts, verify identities, and for tax purposes. Payment card details for both Creators and Fans are processed through third-party providers and we do not receive full card details.
Certainly! Here is the continuation of the Ponsly Privacy Policy:
---
### **Transaction Data**
Collected for both Creators and Fans to facilitate transactions, such as:
**Creators:**
- Earnings
- Payout requests
- Payments made to or from your Creator account
- Failed payments
**Fans:**
- Payments made from your Fan account to Creators
- Failed payments
### **Technical Data**
Collected for both Creators and Fans to monitor and improve the platform:
- Internet or other electronic network activity information, including:
- Internet Protocol (IP) address (and country code)
- User agent (the information your browser provides)
### **Usage Data**
Collected to understand how the platform is used by Creators and Fans:
- Cookies: Necessary cookies are used to allow you to browse the Services and access certain pages of Ponsly. Non-essential cookies are used (with your consent) to recognize Referring Users and Referred Creators under our Referral Program.
Please see our Cookie Notice for more information on the use of cookies.
### **Face Recognition Data**
For Creators, Content Collaborators, and Fans (where applicable):
As described in more detail in Section 9 (Our Onboarding Processes), during onboarding, our third-party providers may use face recognition technology to digitally verify your identity. Face Recognition Data is collected by, and remains with, our third-party provider. We do not collect, receive, possess, or have access to Face Recognition Data at any time.
---
## Our Onboarding Processes
### CREATORS
We have processes in place to ensure that Creators on Ponsly: (i) are at least 18 years of age, and (ii) verify their identity. Before you can start a Creator account, we will:
- Ask you to provide Creator User Data as set out in Section 8 (Categories of Personal Data).
- Check your country of residence to ensure lawful access to Ponsly and the Services.
- Ask you to provide Financial Data as set out in Section 8 (Categories of Personal Data) to process payments and ensure compliance with anti-fraud measures.
- Ask you to go through a third-party age and identity verification process, as described below.
- Ensure that you have not previously been banned from using Ponsly or our Services (e.g., for violating our Terms of Service).
### CONTENT COLLABORATORS
We have processes in place to ensure that Content Collaborators on Ponsly: (i) are at least 18 years of age, and (ii) verify their identity. Before you can feature in content uploaded by a Creator, you will be asked to go through a third-party age and identity verification process, and may also be required to provide a release form.
### FANS
We have processes in place to ensure that: (i) all Fans on Ponsly are at least 18 years of age, and (ii) Fans in certain circumstances or locations verify their identity. Before you can start a Fan account, we will:
- Ask you to provide Fan User Data as set out in Section 8 (Categories of Personal Data).
- Check your country of residence to ensure lawful access to Ponsly and the Services.
- Ask you to provide Financial Data as set out in Section 8 (Categories of Personal Data) to process payments and ensure compliance with anti-fraud measures.
- Ask you to go through a third-party age verification process in certain circumstances or locations.
---
## Third-Party Age and Identity Verification
We use third-party providers to conduct age and identity verification. This process involves:
- Collecting a short .gif, taken from a "selfie" and a photo from a government identity document, both provided to the third-party provider.
- The third-party provider uses Face Recognition Data to match the two images and digitally verify your age and identity.
As described in Section 8 (Categories of Personal Data), we do not collect, receive, possess, or have access to any Face Recognition Data collected or processed by our third-party providers through this process.
Where permitted by applicable law, we receive Third-Party Onboarding Data as set out in Section 8 to maintain a record of the age and identity verification process.
---
## How / Why Your Personal Data is Used and Lawful Bases for Processing
We process Personal Data for, or based on, one or more of the following legal bases:
1. **Consent**: Your consent is required in certain situations, for example, the processing of Face Recognition Data by our third-party providers as part of the age and identity verification process.
2. **Performance of a Contract**: By using the Services, you have contracted with us through our Terms of Service, and we process Personal Data to perform that contract (e.g., fulfilling transactions between Fans and Creators, processing Creator earnings).
3. **Legitimate Interests**: We may process Personal Data if it is in our legitimate interests (or a third party's legitimate interests). This may include investigating and responding to intellectual property claims or protecting user safety.
4. **Compliance with Legal Obligations**: We may process Personal Data to comply with applicable laws, rules, and regulations (e.g., financial or tax reporting requirements).
5. **Task Carried Out in the Public Interest**: We may process Personal Data as necessary for a task carried out in the public interest, such as reporting illegal activity to law enforcement.
---
## Sharing Your Personal Data
We share Personal Data with the following categories of third parties:
1. **Our Third-Party Service Providers**: These include IT, payment processing, customer support, content moderation, and age and identity verification service providers. The lawful basis for sharing Personal Data with these recipients is that it is necessary for our legitimate interests in receiving services that support business functionality.
2. **Our Professional Advisors**: This includes legal advisors, accountants, auditors, and insurers. These parties process Personal Data as necessary to provide their services to us.
3. **Corporate**: Relevant third parties in the event of a possible sale, merger, acquisition, or business reorganization. We share Personal Data when it is necessary for our and the relevant third parties' legitimate interests in assessing and executing such transactions.
4. **Relevant Authorities, Regulators, and Organizations**: We may share Personal Data with governmental authorities, regulators, and organizations for regulatory or legal reasons. The lawful basis for sharing Personal Data in these cases depends on whether the processing is necessary for compliance with legal obligations, legitimate interests, or public interest.
---
## International Data Transfers
We share your Personal Data within our group companies and with third parties as outlined in Section 12 (Sharing Your Personal Data). In some cases, this will involve transferring your data outside France, the European Economic Area (EEA), and Switzerland. We ensure that these transfers are made using appropriate safeguards, including adequacy decisions, standard contractual clauses, or other lawful mechanisms.
---
## Your Rights Regarding Personal Data
You have certain rights regarding your Personal Data, including:
1. **Withdraw Consent**: You may withdraw your consent to processing where applicable, although this will not affect the lawfulness of processing before withdrawal.
2. **Request Access**: You may request a copy of the Personal Data we hold about you.
3. **Request Correction**: You may ask for correction of any inaccurate or incomplete data.
4. **Request Deletion / Erasure**: You may request deletion of Personal Data, subject to legal exceptions.
5. **Request Restriction**: You may ask for restricted processing of your Personal Data under certain conditions.
6. **Request Transfer**: You may request that certain Personal Data be transferred to another party.
If you wish to exercise these rights, please contact us using the contact details provided in Section 19.
---
## Retention of Personal Data
We will only retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected. The retention period varies depending on the nature of the data and the legal requirements:
- **Providing Services**: We retain your Personal Data for the lifetime of your account or as necessary to provide specific features.
- **Trust and Safety**: Personal Data may be retained to investigate suspected violations of our Terms of Service or illegal activity.
- **Legal and Regulatory Compliance**: For example, certain tax or financial records may be retained for up to 7 years to comply with legal obligations.
- **Legal Claims**: Data may be retained in accordance with statutory limitation periods.
---
## Assistance and Contact Information
We have appointed a Data Protection Officer (DPO) responsible for responding to privacy-related questions, requests, and concerns. If you have questions about this Policy or our processing of your Personal Data, you may contact us via:
- Email: privacy@ponsly.com
- Address: Langerouge SASU, 231 rue Saint-Honoré, 75001 Paris, France
