By using JustFans, you confirm that you have read and understood this Privacy Policy.

Introduction
What is personal data?
Please let us know if anything changes
Validity of this policy (18 years and older)
Links to other websites
What if you don’t want to provide personal data
Changes to this policy
What types of personal data we process
Our registration process (Onboarding)
How and why we use your personal data – and on what legal basis
How we obtain your personal data
When we share your personal data
International transfer of your data
Your rights regarding personal data
How to exercise your rights
Your choices and control over your data
How long we keep your data
Additional privacy notes for U.S. states
Help and contact information

1. Introduction

ZVN Digital Limited respects your privacy and is committed to protecting your personal data. ZVN Digital Limited is the owner and operator of just.fans ("Just Fans"). Just Fans is a social network and content-sharing platform where:

(i) Creators (i.e., content creators) share their own content and earn money from it – they can also subscribe to and view content from other creators;

(ii) Fans subscribe to and view content from creators.

This Privacy Policy (“Policy”) explains how we process your personal data when you use Just Fans – whether you are a creator, a fan, or someone who appears in uploaded content (we refer to these individuals as “Content Collaborators”).

It also explains how we process data in the context of business relationships. We process your personal data when you use Just Fans and when we provide you with our services (the “Services”). In this context, we are the so-called “controller” of your data. This means that we determine the purposes and means of processing your data.

If you have any questions about this Policy or about how your data is processed, please refer to Section 19 – it explains how you can contact us.

2. What is personal data?

“Personal data” refers to information that relates to you or can be associated with you. This can include things that directly or indirectly identify you – such as your name, email address, or IP address. Information linked to your household also falls under this category.

Sometimes we also collect data that cannot be linked to you – for example, when it is anonymous, aggregated, or de-identified. This type of data is not considered personal data, and therefore, this Privacy Policy does not apply to it.

3. Let us know if anything changes.

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your data changes while you are using JustFans. You can update or correct your information at any time through the account settings in your JustFans profile.

4. Validity of this Policy (18+ only)

This Policy is provided in addition to our Terms of Use (including the Acceptable Use Policy) and is not part of those Terms. The Terms of Use govern your use of JustFans and the services offered through it. Our services are intended for individuals aged 18 and over only. Use by anyone under the age of 18 is prohibited. By using JustFans, you confirm that you are at least 18 years old.

5. Links to other websites

JustFans may contain links to external websites, plug-ins, or third-party applications. If you click on or activate such links, third parties may collect or share personal data about you.

We are not responsible for the content, security, or privacy practices of these third-party websites, plug-ins, or applications. This Policy does not apply to such external services.

We recommend that you carefully read the privacy and cookie policies of the respective third parties to understand how they use your data.

6. If you don’t want to provide personal data?

We need to collect certain personal data from you in order to provide access to our services or specific features and offerings on JustFans – as outlined in our Terms of Use.

We are also legally required to process certain personal data, for example, for age verification, identity checks, or tax compliance.

Please note: If you choose not to provide the requested data, we may not be able to grant you access to JustFans or certain features and content.

7. Changes to this policy

We may update this Policy from time to time. Any changes will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Policy.

8. Categories of Personal Data

We – or third parties acting on our behalf – process different types of personal data about creators, content collaborators, and fans. For clarity, we have grouped this data into the following categories:

a. User Data

Description for Creators and Content Collaborators:

Full name *
Alias / stage name (if applicable)
Residential address
Place of birth (city)
Country of birth
Country of residence *
Email address
Phone number
Copy of a government-issued ID *
Selfie holding the ID document *
Social media handle or personal website(for additional verification of age and identity and to better understand the nature of your content)
Signature on a consent form if you appear in a creator’s content *

Note: All fields marked with * are also required from content collaborators when a consent form is necessary.

Description for Fans:

Email address
Phone number

Description for Creators and Content Collaborators:

If age and identity verification is required: Copy of a government-issued ID
Result of the age or identity verification (Passed / Not passed + reason)
Verification metadata (e.g., start and end time)

For more details, see Section 9 (Our Onboarding Process). Note: The Third-Party Onboarding Data and Technical Data do not include Face Recognition Data – these are handled separately.

c. Account Data

Description for Creators:

Profile name
Password
Avatars and header images of your creator account
Your subscriptions, subscribers, and referral participants
Posts you have published through your creator account
Comments on posts you have published
Chat messages between you and other users
Support requests you have submitted to us

Description for Fans:

Profile name
Password
Avatars and header images of your fan account
Your subscriptions
Comments on posts you have commented on
Chat messages between you and other users
Support requests you have submitted to us

d. Financial Data (Payment Information)

Description for Creators:

Payment card details *
Billing address
Deposited wallet balance
Bank account information
Payout country
Business or company details (name, country, identification number, and type of identification)
VAT identification number (VAT ID)
Tax identification number and issuing country
Form W-9 (for US creators only)
Form 1099-MISC (for US creators only)
Form 1099-NEC (for US creators only)

Description for Fans:

Payment card details *
Billing address
Deposited wallet balance

Note:Payments for accessing creator content are processed via third-party payment services. JustFans does not receive your full card number, expiration date, or security code. Instead, we receive a token from our payment provider that represents your account, the card’s expiration date, card type, and the first six and last four digits of your card number.

e. Transaction Data

Description for Creators:

Earnings
Payout requests
Payments made to your creator account
Payments you have sent from your creator account to other creators
Failed payments

Description for Fans:

Payments you have made from your fan account to creators
Failed payments

f. Technical Data

Description for Creators and Fans:

Information about your internet or network activity, including:

IP address (including country code)
User agent (e.g., browser used, operating system, device type)

g. Usage Data

Description for Creators and Fans:

We use essential cookies to enable your use of the platform and access to certain pages.
With your consent, we use non-essential cookies to identify referring users and referred creators as part of our referral program (in accordance with our Terms of Use).
For more information on our use of cookies, please refer to our Cookie Policy.
We do not currently use cross-site tracking technologies.
We do not sell personal data or share it for cross-context behavioral advertising.

h. Face Recognition Data

Description for Creators, Content Collaborators, and Fans (where applicable):

As part of the onboarding process (see Section 9), our third-party providers may use facial recognition technology to digitally verify your identity.
Facial recognition data is collected and stored exclusively by the third-party provider.
JustFans does not have access to this data at any time, does not store it, and does not process it.

10. How and why we use your personal data – and on what legal basis

We process personal data based on one or more of the following legal grounds:

Consent:

Your consent is obtained only in certain cases.
For example, for the processing of (i) facial recognition data by our third-party providers in the context of age and identity verification for all creators (and for fans in certain cases or regions),
and (ii) for age estimation, which may also involve facial recognition, by our third-party providers for fans in certain regions.
Further information can be found in Section 9 (Our Onboarding Processes).

Contract Fulfillment:

When you use our services, you enter into a contract with us, as stated in our Terms of Use.
We process personal data to fulfill this contract.
This includes, for example, transactions between fans and creators or payouts to creators.
It also includes the enforcement of contract terms.

Legitimate Interest:

We are allowed to process personal data if we or a third party have a legitimate interest in doing so (see the table below).
This may be the case, for example, when we review a copyright infringement notice (DMCA process) or protect a creator's intellectual property rights.

Legal Obligations:

We process personal data when we are legally required to do so.
This applies, for example, to tax or financial regulations that apply in our jurisdictions.

Task in the Public Interest:

In certain cases, we process personal data when it is in the public interest.
For example, when we need to report illegal activities to authorities, law enforcement, or certain organizations.

We use your personal data only for the purpose for which it was originally collected. Only when there is a legitimate reason that aligns with this original purpose can we use your data for another, but related, purpose.

The following overview shows why we process your personal data and on what legal basis. Some of these reasons overlap, and there may be multiple legal grounds for the same data processing.

Legal Basis for Processing

Account creation (for creators and fans): Legal basis: Contract fulfillment
Age and identity verification for creators and content collaborators, and potential later verification (especially regarding facial recognition data):
Age and identity verification for fans in certain cases or regions, and potential later verification (especially regarding facial recognition data):
Age estimation for fans in certain regions (with potential use of facial recognition): Legal basis: Consent
Age verification for fans without third-party providers or age estimation: Legal basis: Contract fulfillment
Verification of the validity of ID documents and documentation of the verification process: Legal basis: Contract fulfillment
Documentation of the age estimation process (for fans in certain regions): Legal basis: Contract fulfillment
Provision of services (e.g., creator content, transactions between fans and creators, payouts to creators): Legal basis: Contract fulfillment
Referral of recommended users and creators in the referral program: Legal basis: Consent
Communication via the services, e.g., for support requests or changes to the Terms of Use: Legal basis: Contract fulfillment
Enforcement of our Terms of Use and other rules (e.g., acceptable use policies): Legal basis: Contract fulfillment
Moderation and filtering of: Uploaded content, Live streams, Chat messages for monitoring rule violations. Legal basis: Contract fulfillment
Filtering of direct messages for rule violation checks: Legal basis: Contract fulfillment
Removal of illegal content and blocking or disabling user accounts: Legal basis: Legal obligation & contract fulfillment
Removal of content violating our rules, and potential blocking or deactivation of accounts: Legal basis: Contract fulfillment
Maintaining a list of blocked users to prevent further access: Legal basis: Legitimate interest
Reporting illegal activities to authorities or organizations: Legal basis: Legal obligation, legitimate interest, public interest
Disclosure of information to authorities upon requests or investigations: Legal basis: Legal obligation, legitimate interest, public interest
Storage and transfer of data in the context of legal proceedings: Legal basis: Legitimate interest
Compliance with legal regulations, rules, and requirements: Legal basis: Legal obligation & legitimate interest
Monitoring transactions, systems, and networks to detect fraud or attacks and protect data security: Legal basis: Legitimate interest & significant public interest
Protection of the rights and property of our users, our company, and third parties: Legal basis: Legitimate interest

11. How we obtain your personal data

We collect your personal data from the following sources:

Directly from you. When you provide us with your data, for example, when creating an account or using our services. This also includes when you update your data in your account or communicate with us (e.g., user data, account data). We also process your data when you interact with us on third-party websites through our social media pages.
Automatically or indirectly from you. For example, through your use of our services (e.g., transaction data, technical data, usage data). Or when you sign up for JustFans via a third-party account or link another account to your JustFans account.
From our service providers. For example, we receive – as permitted by law – certain onboarding data and technical data from our third-party providers that carry out age and identity verifications.

12. When we share your personal data

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

Our external service providers. For example, IT service providers, payment processors, customer support, content and text moderation, tax automation, and age and identity verification or age estimation providers. The legal basis for sharing data is our legitimate interest – the need to use external services to operate our business.
Our professional advisors. This includes, for example, lawyers, banks, auditors, tax advisors, business consultants, and insurers. These advisors process personal data as necessary to provide us with their services. The legal basis is our legitimate interest – receiving professional support for our business.
Companies in the event of acquisitions or restructurings. Relevant third parties in connection with a potential sale, merger, business acquisition, or restructuring. The legal basis is our legitimate interest and the legitimate interest of the involved third parties – for example, to evaluate and carry out such transactions.
With our affiliated companies. For central management and administration of our business – as described in Section 8 ('Categories of Personal Data'). These companies process personal data according to the same rules outlined in this privacy policy. The legal basis is our legitimate interest – coordinating our business operations worldwide.
Authorities, regulators, and organizations. This includes government agencies (e.g., law enforcement, tax authorities), regulatory bodies, and certain non-profit organizations (e.g., the National Center for Missing & Exploited Children – NCMEC). These bodies use your personal data in the context of their legal or non-profit duties. The legal basis for sharing may vary depending on the situation. It could be based on a legal obligation, a legitimate interest of us or third parties, or the public interest. Examples include: reporting illegal content, supporting requests from authorities, protecting the safety of our users, or complying with tax and financial regulations (e.g., DAC7 in the EU).

13. International transfer of your data

We share your personal data within our corporate group and with third parties, as described in Section 12 ('Sharing Your Personal Data').

In some cases, this means your data will be transferred to countries outside the United Kingdom, the European Economic Area (EEA), and Switzerland. Such transfers are made: (i) to countries that provide an adequate level of data protection, (ii) with appropriate safeguards, or (iii) when legally permitted.

If you would like to learn more about the specific safeguards we use when transferring your data abroad, you can contact us using the contact details provided in Section 19 ('Help and Contact Information').

We take steps to ensure that your data is protected in accordance with applicable data protection laws, regardless of where it is processed.

14. Your rights regarding personal data

You have certain rights regarding the collection and processing of your personal data. You can exercise these rights by contacting us using the contact details provided in Section 19 ('Help and Contact Information').

Under certain circumstances and with some exceptions, you have the right to:

Withdraw your consent to the processing of your personal data. Please note: Withdrawing your consent does not affect the lawfulness of processing before the withdrawal.

Request access to your personal data. You can request a copy of the data we have stored about you and check whether we are processing it lawfully.

Request correction of your stored data. You can have incomplete or incorrect data corrected.

Request deletion of your data. You can request that we delete your personal data if there is no legal reason to keep or process it. You can also request deletion if you exercise your right to object (see below). Please note: In some cases, we may not be able to delete your data for legal reasons – for example, if your account has been suspended due to a violation of our Terms of Use. More details can be found in Section 17 ('Data Retention').

Request restriction of processing. You can ask us to suspend processing while we verify the accuracy of your data or the purpose of processing.

Request the transfer of certain data to another entity.

Object to the processing of your data. This applies if we rely on legitimate interest as the basis for processing and you have a particular reason to object.

We do not carry out fully automated decisions that have legal or similar effects on you.

You also have the right to: File a complaint with a data protection authority. In the UK, this is the Information Commissioner's Office (ICO); in Switzerland, it is the Federal Data Protection and Information Commissioner (FDPIC). If you live in the EEA, you can also contact the national data protection authority responsible for your region.

Depending on your location in the United States, you also have the right not to be discriminated against or penalized for exercising any of these rights, or to contest a decision we made related to your data privacy concerns.

More details can be found in Section 18 ('Additional Data Privacy Information for U.S. States').

15. How to exercise your rights

If you want to exercise your rights under Section 14 ('Your Rights Regarding Personal Data'), you can contact us using the contact details provided in Section 19 ('Help and Contact Information').

When submitting your request, please ensure you provide enough information so that we can confirm your identity and understand, review, and respond to your request.

To verify your identity, we may need to request additional personal data from you, depending on our relationship with you and the sensitivity of your request. In some cases, we may need to decline a data privacy request, especially if we cannot clearly confirm your identity.

If your request is made by someone you have authorized, we will also need proof that the person is entitled to submit the request on your behalf – such as a signed document or a valid power of attorney.

16. Changing and Deleting Your Personal Data

If you have an account with us, you can adjust your account settings on JustFans yourself. Please note that it may take some time for changes to take effect.

Access to Device Information. You can control the services' access to your technical data through the 'Settings' app on your device. For example, you can disable access to network devices or your location there.

Unsubscribing from Email Notifications. We currently do not send emails for direct marketing purposes. However, we send you emails with information about your account (e.g., as a Creator, for new subscribers, received tips, or subscription renewals). You can disable certain types of emails by changing your notification settings on JustFans. You can also send us an email – the contact details are in section 19 ('Help and Contact Information'). Please include 'Unsubscribe from Email Notifications' in the subject line and provide your name and account email address in the email.

Please note that you cannot unsubscribe from certain automatic email notifications. These include emails that are necessary to provide the services to you or to comply with legal requirements (e.g., account confirmation, payment information, changes to features, or technical/security-related notices).

17. How long we store your data

We store your personal data only as long as necessary to fulfill the purposes for which it was collected – as described in this policy. The data we store and how long we store it depends on the individual case and will be determined based on the situation.

We generally set the retention periods for personal data as follows:

Provision of Our Services

When we need your data to provide you with our services or certain features, we store it as long as your account exists or as long as necessary to provide you with the respective feature.

Security and Trust

If you have violated our terms of use (or we suspect a violation), or if we need to retain data to detect and report illegal activities or to protect the security of our users and third parties, we store certain data for as long as necessary. This may be required for internal investigations or to support authorities or organizations such as NCMEC. Longer storage may also be necessary to permanently block certain users or content.

Compliance with Legal Regulations and Obligations

In some regions, there are regulations requiring the retention of identity verification or tax-related data – sometimes up to 7 years.
If we receive a legally valid request (e.g., a court order or search warrant).
If we need to cooperate in a regulatory investigation or legal proceeding. If the law requires a shorter retention period, we will delete the data earlier.

Legal Claims

Personal data is stored in accordance with legal statute of limitations. In certain cases, we may need to retain data longer, for example, to defend against legal claims or complaints.

18. Additional privacy notes for U.S. states

This information will be added later.

19. Help and contact information

We have appointed a Data Protection Officer ('DPO'). This person, along with our data protection team, is responsible for responding to questions, requests, and concerns regarding this policy and the processing of your personal data.

If you have any questions about this policy or how we process your data, you can submit a support ticket through your account or email us at privacy@justfans.io.