Privacy Policy

Last updated October 2026

This Privacy Policy explains how Vallara, Inc. collects, uses, shares and keeps personal data when you use PlayHouse at playhouse.fans, and the choices and rights you have. It applies to Fans, Creators, Agencies and their team members, people who appear in Creators' Content as co-performers, visitors who are not signed in, and people who contact us or who are the subject of a report or request.

The short version:

We do not sell your personal data, and we do not share it for targeted or cross-context behavioral advertising. PlayHouse has no advertising and uses no cross-site tracking.
We verify age and identity. Creators and co-performers verify their identity, and Fans pass an age check before they can see paid or sensitive content. Face-based checks are carried out by our identity verification provider, which asks for your consent first. We keep the results, not your face images.
We check uploads for safety, using hash matching (including Microsoft PhotoDNA) and automated image and video classification tools, and we report apparent child sexual abuse material to the National Center for Missing & Exploited Children (NCMEC), as US law requires.
Messages on PlayHouse are private between the people in the conversation, but they are not end-to-end encrypted. Automated checks and, where something is flagged or reported, trained staff can review them for safety.
Analytics cookies are off until you choose Accept. If you decline, or your browser sends Global Privacy Control, we count visits anonymously without cookies. You can change your choice at any time with the Cookie settings link at the bottom of every page.
Marketing and follower emails are on by default. You can turn each type off at any time in Settings → Email or with the one-click unsubscribe link in every marketing email.
You can delete your account yourself in Settings → Account → Delete account. To ask for a copy of your data, a correction or anything else, use our legal request form and choose "Privacy or data".

Who we are
About this policy
Personal data we collect
Where we get personal data
How we use personal data and our legal bases
Age and identity verification
Biometric data notice
Content safety processing
Automated decisions
Analytics, session replay and error reports
Emails and notifications
Who we share personal data with
International transfers
How long we keep personal data
How we protect personal data
Your rights
EU, EEA and UK
US state privacy rights
Canada
Australia
Other countries
How to exercise your rights
Children
Changes to this policy
Contact us and our Data Protection Officer

1. Who we are

1.1 PlayHouse is owned and operated by Vallara, Inc., a Delaware corporation ("Vallara", "we", "us", "our"). Vallara is the controller of the personal data described in this policy (in US state law terms, the "business"), which means we decide why and how it is processed.

1.2 Our mailing address is Vallara, Inc., 2261 Market Street #67575, San Francisco, CA 94114, United States.

1.3 We have appointed a Data Protection Officer, who is responsible, with our privacy team, for answering questions, requests and concerns about this policy and our use of personal data. We have also appointed representatives in the European Union and the United Kingdom. You can contact our Data Protection Officer and our EU and UK representatives through our legal request form: choose "Privacy or data". For help with your account, use the help center contact form.

2. About this policy

2.1 This policy covers playhouse.fans and the services we provide through it, including our account pages and the verification pages our identity verification provider runs for us (together, the "Services"). Terms such as "Creator", "Fan", "Agency", "User" and "Content" have the meanings given in our Terms of Service. This policy sits alongside the Terms but is not part of your contract with us.

2.2 PlayHouse is for adults only. You must be at least 18 years old to use the Services. By using the Services, you confirm that you are 18 or over. See Children.

2.3 "Personal data" means information that identifies, relates to or can reasonably be linked to you, directly or indirectly. Information that has been de-identified or aggregated so that it can no longer reasonably be linked to you is not personal data. Where we hold de-identified information, we keep it in that form and do not try to re-identify it, except as the law allows.

2.4 The Services link to other websites, and some features are provided by other companies (for example, your card issuer or a social profile a Creator links to). This policy does not cover how those companies handle your data; their own privacy policies do.

2.5 Some personal data is needed to provide the Services, or is required by law. If you don't provide it, you may not be able to use some features. For example, a Creator cannot be paid without passing identity verification, and a Fan cannot unlock paid content without passing an age check.

2.6 Please keep your information accurate. You can update most profile and account details in your settings, or ask us to correct anything else through the request form.

3. Personal data we collect

What we collect depends on how you use PlayHouse.

3.1 Everyone with an account

Account details: email address, username, display name, profile photo and banner, bio, any social links you add, your account type, language and currency settings, and security settings (for example, whether you have added an authenticator app). We do not use passwords: you sign in with a one-time code sent to your email.
Sign-in and device data: for each sign-in, your IP address, the approximate location derived from it (city, region, country and approximate coordinates) and your device type; your sign-in history; and the location of your most recent sign-in.
Activity: who you follow and subscribe to, what you view, like, comment on, buy, tip or unlock, the live streams and video calls you join, and your settings and notification preferences.
Content and messages: the posts, stories, media, comments, messages and other Content you create or send, and their metadata (such as when they were sent).
Payments and wallet: your purchases, subscriptions, wallet top-ups and transactions, refunds and chargebacks. Our payment processor holds your full card details; we keep the card information it gives us, such as the card's brand, country and a fingerprint that lets us recognize the same card without knowing its number.
Referrals: if you join through someone's invite link or invite others, who referred whom and any referral earnings or credit. See the Referral Program Terms.
Reports, appeals and support: reports you make, reports made about you or your Content, moderation decisions, the statements of reasons we send you, appeals and their outcomes, and what you tell us when you contact support or send us a request.

3.2 Fans

We do not ask Fans for a date of birth at sign-up.
Age check: before you can see paid or sensitive content, we record how you passed our age check and the outcome. If you pass using a card saved to your account, we use that card's information from our payment processor. If you go through facial age estimation (and, if needed, an ID document check) with our identity verification provider, we receive its result and decision data. See Age and identity verification.

3.3 Creators

Profile and contact details: first and last name, country, mobile number, date of birth, gender (optional) and a referral code (optional).
Identity verification: through our identity verification provider, your ID document, a selfie and liveness check, a match between your face and your ID photo, and screening against sanctions, politically exposed persons and other watchlists. We receive the provider's results and decision data, including details read from your ID document. See Age and identity verification.
Payouts, earnings and tax: the bank account details you add for withdrawals, your earnings, withdrawals and payout records, the records we need for tax and accounting, and any tax information (such as tax forms) we ask for where the law requires it.
Your audience: information about your subscribers and buyers that the Services show you (see Other users).
Co-performers: the @username tags you add for other Creators who appear in your Content, and the release forms linked to your Content.
If you link your account to an Agency, the link and the share you agreed with that Agency.

3.4 Co-performers

If you appear in a Creator's Content and complete our co-performer release form, we collect your name, date of birth and contact details, your signed release and consent record, the Creator or Content it covers, and the results of the identity verification you complete with our identity verification provider (an ID document, a selfie and liveness check, and a face match), as described in section 6.

3.5 Agencies and their team members

Business details and the information and documents we ask for to verify the Agency's business, the accounts of team members (who sign in with their own email address), the Creators linked to the Agency and the agreed shares, and the Agency's wallet, payout details and earnings.

3.6 Visitors who are not signed in

Anonymous, cookieless analytics events (see Analytics), and the IP address and browser information that our hosting and security providers process to deliver and protect the site.

3.7 People who contact us, or who are the subject of a report or request

Support: your name, username (optional), email address, topic and message when you use the contact form.
Legal, privacy and law-enforcement requests: the details you give in the request form. For law-enforcement requests, this includes the agency, officer name, official email address, phone number and address, and the legal documents provided.
Copyright notices: the contact details, signature and statements in a takedown notice or counter-notice sent through our copyright forms.
Removal requests and reports about Content: if you appear in Content on PlayHouse, are named in a report, or ask us to remove an intimate image of you (signed in through Report leaked content or impersonation, or without an account through our intimate image removal form), we process your request, the Content, the report and our review of it.
Hash lists: we receive digital fingerprints ("hashes") of images and videos from NCMEC's Take It Down service and StopNCII.org, which people submit to stop intimate images of themselves from being shared. We receive the hashes, not the images.

3.8 Sensitive data

Some of this data may be "sensitive" or "special category" data under privacy laws: ID document details, biometric data used in face-based checks (which stays with our identity verification provider; see section 7), the contents of your messages, and financial account details. Because PlayHouse is an adult content service, information about the Content you choose to create, view or buy could also reveal information about your sex life or sexual orientation. We do not verify the accuracy of any such inference, we do not use this information to profile you or for advertising, and we use sensitive data only for the purposes described in this policy, with the safeguards described in it.

4. Where we get personal data

From you, when you sign up, complete your profile, post, message, buy, verify, sign a release form, report, or contact us.
Automatically, from your browser or device when you use the Services: IP address, device type and activity. We work out your approximate location (city, region, country and approximate coordinates) from your IP address. We do not collect precise GPS location from your device.
From our identity verification provider: the results and decision data from identity verification, business verification and age checks, including sanctions and watchlist screening and IP analysis.
From our payment processor: payment results and card information (brand, country and fingerprint), and signals that help prevent fraud.
From our security providers: the result of the bot check at sign-in and other security signals.
From safety tools and organizations: the results of automated image and video classification, and hash matches from Microsoft PhotoDNA, NCMEC's Take It Down list and StopNCII.org.
From other users: reports, messages, comments and Content that mention or depict you; co-performer tags and release forms; a member's invite link if you sign up through it; and, for linked Creators, actions taken by their Agency's team.
From others who contact us: copyright complainants, people reporting Content or asking for its removal, and law-enforcement and government authorities.

5. How we use personal data and our legal bases

5.1 We use personal data only for the purposes below, or for other purposes that are compatible with them or that the law allows. If you are in the EU, the EEA or the UK, the table also shows the legal basis we rely on under the GDPR and the UK GDPR. Some purposes overlap, and where more than one basis is listed, the one that applies depends on the situation and the data involved.

Purpose	Personal data used	Legal basis (EU, EEA and UK)
Creating and running your account, signing you in with one-time codes, and keeping your settings	Account details, sign-in and device data	Contract
Providing the Services: posts, stories, subscriptions, purchases, tips, messages, live streams, video calls and requests, the wallet and Agency features	Account details, activity, Content and messages, payments and wallet	Contract; legitimate interests (providing and developing the Services)
Taking payments, handling refunds and chargebacks, and keeping payment, tax and accounting records, including reporting to tax authorities where the law requires	Payments and wallet, card information from our payment processor, account details, tax information	Contract; legal obligation; legitimate interests (preventing payment fraud and defending chargebacks)
Paying Creators, Agencies and referral earnings	Payout details, earnings, verification results, referral records	Contract; legal obligation
Verifying the identity and age of Creators and co-performers, verifying Agencies' businesses, keeping co-performer release forms, and screening against sanctions and watchlists	Profile details, ID document details and verification results, release forms, business details, screening results	Contract; legal obligation (where a law requires us to verify, keep records or screen); legitimate interests (keeping minors and people who have not consented off PlayHouse, and preventing fraud and sanctions breaches)
Checking that Fans are 18 or over before they see paid or sensitive content	Age check route and outcome, card information from our payment processor, age check results	Contract; legal obligation (where an age-assurance law applies); legitimate interests (keeping minors away from adult content)
Face-based checks (liveness, face match and facial age estimation) carried out by our identity verification provider	Biometric data from your selfie, liveness video and ID photo	Consent, given on our provider's consent screen before the check (see Biometric data notice)
Checking uploads and text for illegal and prohibited material, reviewing reported and flagged items, and enforcing our Terms and Acceptable Use Policy	Content and its metadata, messages and captions, account details, reports, device data	Contract; legal obligation (removing illegal content); legitimate interests (protecting children, people depicted in Content and our users); substantial public interest (preventing and detecting unlawful acts and safeguarding children), where the law provides for it
Keeping a record of banned users, so they can't return to PlayHouse	Account details, verification results, card fingerprint, device data	Legitimate interests
Reporting apparent child sexual abuse material to NCMEC, preserving evidence, and responding to law-enforcement requests	Content, account details, device data, payment records	Legal obligation; legitimate interests (protecting children and the public); task carried out in the public interest or substantial public interest, where the law provides for it
Handling reports, removal requests, appeals, copyright notices, support requests and privacy requests, and sending statements of reasons and outcome notices	Reports, requests, appeals, notices, messages to us, account details	Contract; legal obligation; legitimate interests (resolving disputes and protecting rights)
Keeping the Services secure: bot checks, preventing fraud and account takeover, complying with sanctions laws, and investigating incidents	Sign-in and device data, approximate location, card fingerprint, verification results	Legitimate interests (security and fraud prevention); legal obligation
Sending service emails and notifications you need (sign-in codes, receipts, security, account, moderation and policy notices)	Email address, account details, push subscription	Contract; legal obligation
Sending marketing emails, and follower emails about new posts and live streams from Creators you follow	Email address, follows and subscriptions, email preferences	Legitimate interests (telling our users about PlayHouse and the Creators they follow). You can opt out at any time (see Emails and notifications)
Anonymous, cookieless analytics and error reports	Pages visited (path only), masked interactions, error details	Legitimate interests (understanding and improving the Services and fixing faults)
Analytics cookies and session replay, after you choose Accept	A cookie identifier, masked interactions and recordings	Consent
Account events we record in our analytics tool against your user ID (see Account events)	User ID, verification status, Creator activation, a Creator's first earning	Legitimate interests (understanding and improving verification and Creator onboarding)
Establishing, exercising or defending legal claims, and in a sale, merger, financing or reorganization of our business	Any relevant data	Legitimate interests; legal obligation

5.2 Where we rely on legitimate interests, we have balanced our interests against your rights. You can ask us for more information about that balance, and you can object (see Your rights). Where we rely on consent, you can withdraw it at any time; this does not affect processing that took place before you withdrew it.

6. Age and identity verification

6.1 We verify age and identity to keep minors and people who have not consented off PlayHouse, to meet our legal obligations, and to prevent fraud. A specialist identity verification provider runs the checks on our behalf, as our service provider. For more detail, see Age and Identity Verification.

6.2 Creators and co-performers

Creators give us their date of birth (they must be 18 or over) and then complete our provider's verification: an ID document check, a selfie and liveness check, a face match between the selfie and the ID photo, sanctions and watchlist screening, and an analysis of the IP address used. A Creator must pass verification before they can be approved and before any payout. A co-performer who completes a release form goes through the same identity and age verification before the release is accepted.

6.3 Fans

Fans pass an age check before they can see media in direct messages, unlock paid content, subscribe, buy VIP message credits or live stream tickets, join live streams, or turn on sensitive content. We use the first of these routes that applies to you: an approved Creator verification on your account; a credit card saved to your own account (debit and prepaid cards don't count); or facial age estimation by our provider, followed by an ID document check if the estimate is close to the age threshold. If those routes don't resolve it, a member of our team reviews the case. The same routes apply in every country. If a check shows you are under 18, or you don't pass, the check is declined, we tell you by email, and sensitive and paid content stay off for your account.

6.4 Agencies

Before we approve an Agency, we verify its business. We may ask for business registration details and documents, and for information about the people who own or run the Agency.

6.5 What we keep

We keep the verification results and decision data, such as the outcome of the ID, liveness, face-match, screening and device checks, and details read from the ID document.
We do not copy ID document images or face images into our own systems. Our provider holds them on our behalf, and authorized staff can view them through the provider's secure systems when they need to review a verification.
We do not collect, receive or keep face templates or other biometric data (see section 7).

7. Biometric data notice

This notice applies to everyone who completes a face-based check, and is given in particular for residents of Illinois, Texas, Washington, Colorado and other places with laws on biometric identifiers, biometric information or consumer health data.

What is collected: during a check, our identity verification provider captures your selfie and a short liveness video (your session video is recorded) and, if an ID document is used, the photo on that document. From these, the provider uses facial recognition technology to check that you are a real, live person, to compare your face with your ID photo, and to estimate your age. The resulting data are biometric identifiers or biometric information under some laws.
Who collects it: our identity verification provider collects, uses and stores this data on behalf of Vallara, Inc., as our service provider. Biometric data stays with the provider: we do not ourselves collect, receive or store it. We receive only the results of the check.
Why: only to verify your age and identity, to detect spoofing and fraudulent documents, and to keep a record that the check took place. We do not use biometric data to identify you anywhere else, we do not run face recognition on the Content you upload, and we do not use biometric data for advertising or analytics.
Notice and consent: before any face-based check starts, our provider shows you a consent screen explaining that the check uses facial recognition to verify your identity and that your session video will be recorded. By selecting Continue on that screen, you consent to the collection, use and storage of your biometric data as this notice describes. If you don't consent, don't continue. Creators and co-performers can't be verified without a face-based check. Fans can instead pass the age check with a credit card saved to their own account.
No sale: we do not sell, lease, trade or otherwise profit from your biometric data. It is disclosed only to our provider, or where the law requires it (for example, under a valid warrant or subpoena).
Retention and destruction: biometric data is permanently destroyed when the purpose for which it was collected has been satisfied, and no later than three years after your last interaction with PlayHouse, unless the law requires us to keep it longer. We keep the verification records described in section 6.5 for as long as we need them for legal, safety and fraud-prevention purposes (see section 14).
Security: biometric data is stored, transmitted and protected using a reasonable standard of care, at least as protective as the way we handle our other confidential and sensitive data.
Washington consumer health data: the only consumer health data, as Washington's My Health My Data Act defines it, that we may process is the biometric data described in this notice. It is collected only with your consent, used only for the purposes above, shared only with our provider, and never sold. You can ask to access or delete it, or withdraw your consent, through the request form.

8. Content safety processing

8.1 To keep illegal and harmful material off PlayHouse, uploads (including posts, stories, vault items, chat media, profile and banner images and custom orders) are checked before they are published or delivered, using:

hash matching, which compares a digital fingerprint of a file with lists of known illegal or non-consensual images, including hash lists from StopNCII.org and NCMEC's Take It Down service;
Microsoft PhotoDNA, which compares a hash of an image with known child sexual abuse material (Microsoft receives the hash, not the image); and
automated image and video classification tools, which receive the image or video and return signals such as nudity, the apparent age of faces, possible deepfakes, self-harm, violence, weapons, drugs and offensive symbols. Apparent age is estimated only to flag possible minors for review; it does not identify anyone.

8.2 When hash lists are updated, we check stored media again.

8.3 Automated text rules check messages, post and story captions, bios and display names for contact and payment details, attempts to take conversations off PlayHouse, and prohibited terms. A hit can hold a message or send it for review.

8.4 People can report Content, accounts, messages, conversations, live streams and calls. Items that are reported or flagged by our automated tools are reviewed by our restricted, specially trained moderation team.

8.5 We report apparent child sexual abuse material to NCMEC's CyberTipline, as US law (18 U.S.C. §2258A) requires. A report can include the Content, account details, IP addresses and other information about the account. NCMEC may share reports with law-enforcement agencies in the US and other countries. We preserve reported material and related data in secure, tamper-proof storage, as the law requires (see Retention). See Combating Child Sexual Abuse Material.

8.6 Live streams and video calls are not recorded.

9. Automated decisions

9.1 Some decisions are made by automated systems, at least at first:

Upload checks can hold Content automatically. Where there is strong evidence of child sexual abuse material (such as a PhotoDNA match), the account is frozen automatically: the user cannot sign in and their earnings are held. A trained reviewer then reviews the case.
Our identity verification provider's checks decide whether a verification or age check passes. If an age estimate is close to the threshold, you are asked for an ID document check, and unresolved cases go to a member of our team.
A Creator account is approved automatically after a passed verification; staff may review it.
Text rules can hold a direct message that contains payment details.

9.2 When we take action on your Content or account, we send you a statement of reasons that explains what we decided and why, and how to appeal. You can appeal a decision about your Content through Appeal a moderation decision, or a decision about your account through our account appeal form. If your account was frozen or your Content removed under our child-safety process, or your Content was removed as non-consensual intimate imagery, you can ask for a review through the request form (choose "Legal inquiry"); a trained reviewer who was not involved in the original decision decides it. Where the law gives you the right to ask for human review of a solely automated decision, or to contest it, you can also ask through the request form. See our Appeals Policy.

10. Analytics, session replay and error reports

10.1 We use an analytics provider that hosts our analytics data in the European Union, for analytics, session replay and error tracking. IP addresses are discarded, and every event is cleaned before it is sent: query strings are removed, and email addresses, tokens and secrets are redacted.

10.2 Before you choose, after you decline, or with Global Privacy Control

A consent bar asks you to Accept or Decline analytics cookies. Until you choose, if you choose Decline, or if your browser sends a Global Privacy Control (GPC) or Do Not Track signal (in which case you won't see the bar and we treat you as having declined):

nothing is stored on your device for analytics;
we still count anonymous, cookieless events: page views (the path only), interactions with all text masked, heatmaps, clicks that don't respond, errors and product events (listed in 10.4). These are counted in a way that cannot recognize you from one day to the next;
no session replay runs; and
nothing is linked to your account.

10.3 If you choose Accept

Our analytics provider stores an identifier in a cookie and in your browser's local storage, for up to 365 days, so that visits from the same browser can be connected.
Session replay may record how pages are used, with all text and inputs masked; images, video, audio and embedded content blocked; and no network data. Replay never runs on sign-in, verification, messages and chat, email verification or account deletion pages. Replays are kept for 30 days.
The PlayHouse website never links browser analytics to your account. It does not tell our analytics provider who you are, and sends no user ID or account type from your browser.

You can change your choice at any time with the Cookie settings link at the bottom of every page; see our Cookie Notice.

10.4 Product events

Product events record actions such as completing sign-up or sign-in, starting, passing or failing an age check, starting or returning from identity verification, purchases (unlocks, tips, subscriptions, VIP credits, tickets and top-ups), sending a message, a report or a support request, and searching the help center. In the browser, these events are anonymous unless you have accepted analytics cookies, and are never linked to your account.

10.5 Account events

Separately from the browser, our servers record a small number of account events in our analytics tool against your PlayHouse user ID. They do not include your email address or name, and they are not geolocated. The events are:

your identity or age verification status;
that a Creator account was activated; and
a Creator's first earning (its type, amount and currency).

Because the browser never tells our analytics provider who you are, these account events are not connected to your browser activity. If you are in the EU, the EEA or the UK, you can object to them (see Your rights).

10.6 Error reports

When something goes wrong on the website (in your browser or on our servers) or in our back-end services, an error report is sent to our analytics provider with secrets, headers, request bodies, cookies and query strings removed. Reports from our back-end services identify the service, not a person.

10.7 We do not use advertising pixels or any other advertising or cross-site tracking technology.

11. Emails and notifications

Service messages: we send emails you need to use your account, such as sign-in codes, receipts, security alerts, verification, moderation decisions and statements of reasons, account notices, and important changes to our terms. You can't turn these off while you have an account.
Marketing and follower emails are on by default. These include product news, a welcome series, tips for Creators, campaigns, and emails when a Creator you follow posts or goes live. You can turn each type off at any time in Settings → Email, and every marketing email has a one-click unsubscribe link. If an email is marked as spam, we stop sending to that address.
Push notifications: if you turn on browser push notifications, the push service run by your browser's maker delivers them. You can choose which ones you get in Settings → Notifications or turn them off in your browser.

12.1 We do not sell personal data, and we do not share it for targeted or cross-context behavioral advertising. We have not done so in the past 12 months. We share personal data only as described below.

These companies process personal data on our behalf, under contracts that limit how they can use it:

Type of provider	What they do for us	Data they receive
Cloud hosting provider (United States)	Hosting, database, file storage, video processing, content delivery and sending email	All data stored on PlayHouse
Security and content-delivery providers	Domain name service, delivering pages and files, security and firewall protection, and the bot check at sign-in	IP address, browser and request data
Payment processor	Card payments, the card-based age check, and fraud prevention	Card details (which the processor holds, not us), payment amounts, and payment and device signals
Identity verification provider	Identity verification for Creators and co-performers, business verification for Agencies, and Fan age checks: ID documents, selfie and liveness, face match, facial age estimation, sanctions and watchlist screening, IP analysis	ID document, selfie and liveness video, biometric data, IP address, name and date of birth from the ID, business details
Analytics provider (hosted in the European Union)	Analytics, session replay and error tracking	As described in section 10
Automated image and video classification tools	Automated safety classification of images and videos	The uploaded media file
Microsoft PhotoDNA	Matching against known child sexual abuse material	Image hashes only
Browser push services	Delivering web push notifications	A push subscription and the notification
IT, software and security tools	Running and securing our systems, our staff's work tools, and receiving reports through our vulnerability disclosure program	Limited data, mainly about our staff and security researchers

Our payment processor and identity verification provider may also use some data for their own fraud-prevention and legal purposes, as their own privacy policies describe.

We report apparent child sexual abuse material to NCMEC, as US law requires (see section 8). We use hash lists from NCMEC's Take It Down service and StopNCII.org (operated by SWGfL); we do not send them your Content.

Your public profile: your username, display name, profile photo, banner, bio and any social links you add, and Content you make public, can be seen by anyone, including people who are not signed in. Public profiles can appear in search engines.
Creators see who follows and subscribes to them, and the purchases, tips, messages and requests their Fans send them.
Messages are seen by the people in the conversation, and comments and live stream activity by the people who can see that post or stream.
Co-performers: a Creator who tags you, or whose Content your release form covers, sees that the tag or release is linked to their Content. Your username appears in the tag.
Agencies: if a Creator links their account to an Agency, the Agency's team members can work in that Creator's account, and the Creator's profile and chats show that an Agency helps manage the account. The team can see and act on the Creator's chats, posts, plans and offers, subscribers, automated messages, lists, insights, live streams, orders and video call hours. This means an Agency's team may read Fans' messages to that Creator and see their purchases from that Creator. Agencies cannot see or change the Creator's security, notification, blocked-list, email, payout or identity details. See our Agency Terms.

We disclose personal data to law-enforcement agencies, courts, regulators, tax authorities and others when we believe in good faith that the law requires it (for example, a valid subpoena, court order or warrant, or tax reporting such as US Form 1099 or EU DAC7 reporting), in an emergency involving a risk of death or serious physical injury, or to protect the rights, property and safety of our users, the public or Vallara. Requests are handled by a restricted team. We may notify a User before disclosing their information, unless the law, a court order or the circumstances (for example an emergency or child-safety case) prevent it. See Assisting Law Enforcement.

Our lawyers, accountants, auditors, banks and insurers, who need it to advise or serve us.
Another company and its advisers in connection with a proposed or actual merger, acquisition, financing, reorganization or sale of all or part of our business. We will require them to protect personal data in line with this policy.
Anyone else, when you ask us to or give your consent.

13. International transfers

13.1 Vallara is based in the United States, and our main systems are hosted in the United States. Analytics data is held in the European Union. Our identity verification provider keeps verification images in its own systems, and our other service providers may process data in the other countries where they operate.

13.2 This means your personal data will be processed in the United States and other countries whose data protection laws may differ from yours. Where the law of the EU, the EEA, the UK or Switzerland requires a transfer safeguard, we transfer data to countries that have been found to provide an adequate level of protection, or we rely on the European Commission's Standard Contractual Clauses (with the UK International Data Transfer Addendum and Swiss amendments where needed) or another mechanism the law allows. You can ask for more information about these safeguards through the request form.

14. How long we keep personal data

14.1 We keep personal data only for as long as we reasonably need it for the purposes in this policy: while your account is open, and after that for as long as we need it for legal, safety, fraud-prevention, tax and accounting purposes, to resolve disputes and enforce our agreements, and to keep banned users off the Services. The period depends on the type of data and why we hold it.

Data	How long we keep it
Account, profile, Content and messages	While your account is open. After an account is deleted, we delete or anonymize this data on a regular schedule, except a limited record of the account that we keep for legal, safety and fraud-prevention purposes.
Payments, wallet ledger, invoices, earnings, payout and tax records	For as long as tax, accounting and anti-fraud laws require, and to handle disputes and chargebacks.
Verification results, decision data and co-performer release forms	While your account is open (or, for a release form, while the Content it covers is on PlayHouse), and afterward for as long as we need them to show that we checked age, identity and consent, to meet legal obligations and to prevent fraud.
Biometric data (held by our identity verification provider)	Destroyed when the purpose for which it was collected has been satisfied, and no later than three years after your last interaction with PlayHouse, unless the law requires longer (see section 7).
IP address and location details on sign-in and activity records (such as views, likes, comments, sessions, posts, stories and orders)	The IP address and approximate location are removed from these records after 90 days; the country and the time of the activity are kept. Your account keeps the location of your most recent sign-in until you next sign in.
Sign-in codes	Deleted after 7 days.
System logs	Between 30 and 400 days, depending on the type of log.
Backups	35 days.
Session replays	30 days.
Safety evidence	Kept in secure, tamper-proof storage for as long as we need it to investigate and enforce our rules; for at least one year after a CyberTipline report, as US law requires; and for longer where law enforcement asks us to preserve it or the law requires.
StopNCII hashes	While they remain on the StopNCII list; hashes withdrawn from the list are deleted within 30 days.
Support, legal and privacy requests	As long as we need them to handle the request and keep a record of how we handled it.

14.2 When you delete your account (in Settings → Account → Delete account, confirmed by email, or through the request form): sign-in sessions are ended; posts and stories are removed; subscriptions are canceled; follows are removed; chats are hidden and the messages you sent are removed from view; and your profile is removed from the list we give search engines. We then delete or anonymize your personal data on our regular deletion schedule, except what we must keep for the purposes in 14.1, such as payment, ledger and invoice records and safety evidence. Copies in backups are overwritten as the backups expire. Creators should withdraw their earnings before deleting their account. If an account is frozen or under investigation, we may not be able to delete it until the matter is resolved.

14.3 We may keep data for longer where the law requires it, where it is needed for an investigation or legal claim, or where it is subject to a preservation request. Where the law sets a shorter period, we follow it.

15. How we protect personal data

We use administrative, technical and physical safeguards designed to protect the personal data we hold, including encryption in transit, access controls and monitoring. Access to personal data is limited to staff who need it for their work, and legal requests and child-safety cases are handled by restricted, specially trained teams. Card numbers are held by our payment processor, not by us, and we do not use passwords. You can add an authenticator app to your account in Settings → Security.

No system is completely secure, and we cannot guarantee the security of your data. If a security incident affects your personal data, we will notify you and the authorities where the law requires. To report a vulnerability, see Security Reporting.

16. Your rights

16.1 Depending on where you live, and subject to legal limits, you can ask us to:

access your personal data and get a copy of it, in a portable format where the law provides for it;
correct personal data that is inaccurate or incomplete;
delete your personal data (you can also delete your account yourself; see section 14);
object to or restrict how we use it, including where we rely on legitimate interests; and
withdraw your consent where we rely on it, for example to analytics cookies or to the retention of your biometric data.

16.2 These rights have legal limits. For example, we may keep data we need to comply with the law, to protect the safety of others (such as safety evidence and records that keep banned users off the Services), to complete transactions or to defend legal claims. If we can't do all of what you ask, we will tell you why, unless the law prevents us.

16.3 You can also turn off marketing and follower emails at any time (see section 11). We will not discriminate or retaliate against you for exercising your rights.

16.4 The sections that follow describe additional rights in particular regions. See How to exercise your rights for how to make a request.

17. EU, EEA and UK

17.1 If you are in the European Union, the European Economic Area or the United Kingdom, the GDPR or the UK GDPR gives you the rights to access, rectification, erasure, restriction of processing, data portability, and to object (including an absolute right to object to direct marketing), the right to withdraw consent at any time, and rights relating to solely automated decisions that have legal or similarly significant effects (see section 9).

17.2 We will respond within one month of receiving your request. The law allows us to extend this by up to two further months for complex or numerous requests, in which case we will tell you. Under UK law as amended by the Data (Use and Access) Act 2025, the time does not run while we wait for information we reasonably need to confirm your identity or to clarify your request, and our searches for your data will be reasonable and proportionate.

17.3 We have appointed representatives in the European Union and the United Kingdom. You can contact them, and our Data Protection Officer, through our legal request form (choose "Privacy or data").

17.4 If you have a concern, please tell us first through the request form so we can try to put it right. You also have the right to complain to a data protection supervisory authority, in particular in the country where you live or work or where you believe the problem occurred. In the UK, that is the Information Commissioner's Office (ico.org.uk). A list of EU and EEA authorities is on the European Data Protection Board website. In Switzerland, you can complain to the Federal Data Protection and Information Commissioner.

17.5 Our legal bases are set out in section 5 and our transfer safeguards in section 13.

18. US state privacy rights

18.1 This section supplements this policy for residents of US states with comprehensive privacy laws, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia, to the extent those laws apply to us. In it, "personal information" has the meaning those laws give it.

18.2 Notice at collection (California)

The table below shows the categories of personal information we collect, examples, and the categories of recipients we disclose them to for a business purpose. We collect it from the sources in section 4, for the purposes in section 5, and keep it for the periods in section 14. We do not sell or share any of it.

Category	Examples	Disclosed for a business purpose to
Identifiers	Name, email address, username, mobile number, IP address, user ID	Service providers; other users (public profile details); Agencies a Creator links to; NCMEC; law enforcement and authorities where required
Customer records (Cal. Civ. Code §1798.80(e))	Name, phone number, bank account details for payouts, card brand, country and fingerprint	Service providers (our payment processor and cloud hosting provider); authorities where required
Protected classification characteristics	Age and date of birth, gender (optional, Creators)	Service providers (our identity verification and cloud hosting providers)
Commercial information	Subscriptions, purchases, tips, wallet transactions, earnings	Service providers; the Creator you buy from and their linked Agency; tax and other authorities where required
Biometric information	Face geometry used by our identity verification provider for liveness, face match and facial age estimation (we receive the results, not the biometric data)	Our identity verification provider, as our service provider
Internet or other electronic network activity	Device type, sign-in history, activity on PlayHouse, analytics events	Service providers (our cloud hosting, security and content-delivery, and analytics providers)
Geolocation data	Approximate location derived from IP address (not precise geolocation)	Service providers; law enforcement where required
Audio, electronic and visual information	Photos, videos and other Content you upload; ID document and selfie images (held by our identity verification provider)	Service providers (our cloud hosting provider, automated classification tools and identity verification provider); other users, as you choose; NCMEC and law enforcement where required
Professional or employment-related information	Creator status and earnings; Agency business details and team roles	Service providers; linked Creators or Agencies
Sensitive personal information	ID document details; account sign-in with a one-time code; bank account details; biometric data; contents of messages; information about sex life or sexual orientation that may be inferred from use of the Services	Service providers; the people you message and, for linked Creators, their Agency; NCMEC and law enforcement where required
Inferences	Age estimate and age check result; safety signals from automated checks	Service providers

18.3 No sale, no sharing, no targeted advertising

We do not sell personal information, share it for cross-context behavioral advertising, or process it for targeted advertising, and we have not done so in the past 12 months. We have no actual knowledge of selling or sharing the personal information of anyone under 16; PlayHouse is for adults only.

18.4 Sensitive personal information

We use and disclose sensitive personal information only for the purposes the California regulations allow without offering a right to limit (such as providing the Services you request, verifying age and identity, security, preventing fraud and illegal activity, physical safety, and complying with the law), and not to infer characteristics about you for any other purpose. For that reason we do not offer a "Limit the Use of My Sensitive Personal Information" link. Where a state law requires consent to process biometric data, we obtain it as described in the Biometric data notice.

18.5 Your rights

Depending on your state, you have the right to:

know or confirm whether we process your personal information, and access it, including the categories of personal information, sources, purposes and recipients, and the specific pieces we hold;
receive a portable copy;
correct inaccurate personal information;
delete personal information;
opt out of the sale or sharing of personal information, targeted advertising, and certain profiling (we do none of the first three);
limit the use of sensitive personal information (see 18.4);
in Oregon, Minnesota, Maryland and some other states, get a list of the specific third parties (or categories of third parties) to which we have disclosed personal information; and
not be discriminated or retaliated against for exercising these rights.

18.6 Making a request, verification and authorized agents

Make a request through the request form (choose "Privacy or data"). To protect you, we verify your identity before acting on a request. We may do this by matching the information you give us with your account, and we may ask for more information where the request is sensitive. You can use an authorized agent; we will ask the agent for your signed permission (or a valid power of attorney) and may ask you to confirm your identity with us directly. We respond within the time the law requires (for example, 45 days under California law, which can be extended once by a further 45 days where reasonably necessary, in which case we will tell you).

18.7 Global Privacy Control

We honor Global Privacy Control. If your browser sends a GPC signal, we treat it as a request to opt out of sale and sharing for that browser (although we do neither) and as a decline of analytics cookies, and we do not show the consent bar.

18.8 Appeals

If we decline your request, in whole or in part, you can appeal through the request form: choose "Privacy or data" and tell us that you are appealing our decision. We will tell you the outcome of your appeal, and our reasons, within the time your state's law requires. If you are not satisfied, you can contact your state Attorney General.

18.9 Notice of financial incentive

Our referral program rewards a member who invites a Creator to PlayHouse with a share of what that Creator earns, for a limited period, as set out in the Referral Program Terms. If we extend the program to referred Fans' spending, the terms will be shown in the product. To run it, we record who referred whom and the resulting referral earnings or credit. Taking part is voluntary, and you can stop at any time by not sharing your invite link or by asking us through the request form. We believe the value of the program is reasonably related to the value of the personal information involved, which we estimate from what it costs us to collect and process that information and to run the program.

18.10 Nevada

We do not sell covered information as Nevada law defines it. Nevada residents can still send us an opt-out request through the request form.

19. Canada

If you are in Canada, you have the right under the Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial laws to access your personal information, to ask us to correct it, and to withdraw your consent, subject to legal and contractual limits. If you are in Quebec, you also have rights under Quebec's Act respecting the protection of personal information in the private sector (as amended by Law 25), including to be told about decisions based solely on automated processing and to submit observations about them, and to receive your computerized personal information in a structured, commonly used technological format. Our Data Protection Officer is the person in charge of the protection of personal information and can be reached through the request form. Your personal information is stored and processed outside Canada, mainly in the United States, and may be accessible to courts and authorities there. You can complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca) or, in Quebec, to the Commission d'accès à l'information (cai.gouv.qc.ca).

20. Australia

If the Australian Privacy Act 1988 and the Australian Privacy Principles apply to your personal information, you can ask to access it and to correct it. Your personal information is disclosed to and held in the United States, the European Union (analytics) and other countries where our service providers operate. If you have a complaint, please contact us first through the request form, and we will respond within a reasonable time. If you are not satisfied, you can complain to the Office of the Australian Information Commissioner (oaic.gov.au).

21. Other countries

If you live in another country with data protection laws (for example Brazil, Japan, South Korea, New Zealand or South Africa), you may have rights similar to those above. We will honor them as your local law requires. Contact us through the request form, and you can also complain to your local data protection authority.

22. How to exercise your rights

Delete your account: go to Settings → Account → Delete account and confirm by email. Creators should withdraw their earnings first.
Copy, deletion, correction, objection or restriction: use the legal request form, choose "Privacy or data", and then "A copy of my data", "Delete my data", "Correct my data", "Object to or restrict processing" or "Something else". Our privacy team handles each request. Please submit it from, or tell us, the email address on your account so we can find and verify it.
Your profile: you can change most profile details yourself in your settings.
Emails: Settings → Email, or the one-click unsubscribe link in any marketing email.
Push notifications: Settings → Notifications.
Analytics cookies: the Cookie settings link at the bottom of every page; see our Cookie Notice.

We don't charge for requests, unless the law allows a fee because a request is manifestly unfounded or excessive. We may decline a request where we can't verify your identity.

23. Children

PlayHouse is only for people aged 18 and over. We do not knowingly collect personal data from anyone under 18, and we do not direct the Services to children. Creators and co-performers must be verified as adults, and Fans must pass an age check before they can see paid or sensitive content (see section 6). Uploads that show signs that a minor may be depicted are held and reviewed, and we report apparent child sexual abuse material to NCMEC as the law requires. If we learn that someone under 18 has an account, we will close it and remove its Content, keeping only what the law requires us to preserve. If you believe a minor is using PlayHouse or appears in Content on it, please report the Content or account, or tell us through the contact form.

24. Changes to this policy

We may update this policy from time to time. We will post the new version here and change the "Last updated" date. If we make material changes, we will tell you before they take effect, for example by email or a notice on PlayHouse. Where the law requires your consent to a change, we will ask for it.

25. Contact us and our Data Protection Officer

For questions about this policy or your personal data, or to contact our Data Protection Officer or our EU and UK representatives, use our legal request form and choose "Privacy or data". You can also write to us at: Vallara, Inc., Attn: Data Protection Officer, 2261 Market Street #67575, San Francisco, CA 94114, United States.