PlayHouse Pty Ltd and its subsidiaries ("PlayHouse", "we", "us", "our") respect your privacy and are committed to protecting the personal data we process about you. PlayHouse is a social network that allows "Creators" to share and monetise their own content, as well as subscribe to and view the content of other Creators. It also enables "Fans" to subscribe to and view the content of Creators.
This privacy policy ("Policy") explains our practices regarding the personal data we process about our Creators, Fans, “Content Collaborators” (individuals featured in uploaded content by Creators), and in the context of our business relationships. The Policy contains specific sections relevant to Creators and Fans.
We process your personal data when you use our website located at www.playhouse.com ("Website") and the services we offer through the Website. We also process your personal data when you interact with us through our social media pages on third-party websites (e.g., Twitter and Instagram) or other channels. Collectively, these activities are referred to as the "Services" in this Policy.
As a “data controller”, we determine the reasons and means by which we process personal data about you.
Please review this Policy to understand how we process your personal data in connection with the Services. By using our Services, you acknowledge that you have read and understood the information in this Policy.
If you have any questions about this Policy or our processing of your personal data, please refer to Section 19 (assistance and contact information) for details on how to contact us.
"Personal data" refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular person or household.
Additionally, we may collect data that does not identify you or is not associated or linked to you, such as de-identified, aggregated, or anonymised information. Such data is not considered personal data, and this Policy does not apply to our use of such data.
It is important to ensure that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes at any point during your relationship with us. You can update or correct your information through your account settings on our Website.
This Policy supplements but does not form part of our Terms of Service, which govern your use of our Website and the Services.
Our Services are intended exclusively for individuals who are 18 years of age or older. Individuals under the age of 18 are not permitted to use the Services. By using the Services, you represent that you are 18 years of age or older.
Our Website may contain 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 the content, security, or privacy practices of those third-party websites, plug-ins, or applications. This Policy does not apply to them. We encourage you to review the privacy and cookie policies/notices of those third parties to understand how your personal data may be used.
To provide you with access to the Services or specific features and functionalities in accordance with our contract with you (i.e., our Terms of Service), we require certain personal data from you. We may also be legally obliged to process certain personal data. Please note that if you choose not to provide the requested personal data, we may be unable to grant you access to the Services or specific features and functionalities.
We may update this Policy periodically, and any updates will become effective when we post the revised Policy on our Website. We will make reasonable efforts to notify you of material updates to this Policy, such as sending feed notifications or chat messages through your account on our Website.
We process different categories of personal data about Creators and Fans, which we have grouped as follows:
Category of Personal Data | Description |
---|---|
User Data |
Creators and Content Collaborators
*Note: These items will be requested for Content Collaborators who are not existing Creators on the Website, through a release form. Fans
|
Third-Party Onboarding Data |
The following types of personal data are collected directly by our third-party providers during onboarding: Creators
Fans
Please refer to Section 10 (our onboarding processes) for more information. Note that Face Recognition Data is not included in Third-Party Onboarding Data and Technical Data. |
Account Data |
Creators
Fans
|
Financial Data |
Creators
Fans
*Note: Payments made to view Creator content are processed by third-party payment providers. We do not receive your full payment card number, expiration date, or security code. Instead, the payment provider provides us with a token representing your account and limited payment card information. |
Transaction Data |
Creators
Fans
|
Technical Data |
Creators and Fans Internet or electronic network activity information, including:
|
Usage Data |
Creators and Fans Cookies, with your consent, for:
More information on cookies, including how to manage them, can be found in our Cookie Notice. Data collected from cookies may be in de-identified, aggregated, or anonymised format. We do not currently use cross-site tracking technologies, and we do not sell or share personal data collected about you for cross-context behavioural advertising. |
Face Recognition Data |
Creators (and Fans in certain locations)
|
CREATORS
We have established processes to ensure that all Creators on the PlayHouse platform meet the following requirements: (i) are at least 18 years of age, and (ii) verify their identity. Before you can create a Creator account, we will:
FANS
We have implemented processes to ensure that: (i) all Fans on the PlayHouse platform are at least 18 years of age, and (ii) Fans in certain locations verify their identity. Before you can create a Fan account, we will:
We process personal data for, or based on, one or more of the following legal basis:
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
The table below outlines the purposes for processing personal data and the lawful basis for each processing activity:
Purpose / Activity | Lawful Basis for Processing |
---|---|
Account creation |
Performance of a contract |
Creator age and identity verification and subsequent authentication (including Face Recognition Data) |
Consent |
Fan age and identity verification and subsequent authentication (including Face Recognition Data) |
Consent |
Fan age estimation (including the age estimation capture, which may involve the use of Face Recognition Data) |
Consent |
Fan age verification (to the extent possible without third-party age and identity verification or age estimation) |
Performance of a contract |
Government identity document validity check and maintaining a record of the age and identity verification process |
Performance of a contract |
Maintaining a record of the age estimation process |
Performance of a contract |
Providing the Services, including hosting content, transaction fulfilment, and processing Creator earnings |
Performance of a contract |
Providing technical support | Performance of a contract |
Communication about the Services, responding to support requests, and sharing information about the Services | Performance of a contract |
Enforcing our Terms of Service and other usage policies | Performance of a contract |
Moderation and filtration, including monitoring and investigating violations of our Terms of Service | Performance of a contract |
Removal of illegal or Terms of Service-violating content and suspension or deactivation of user accounts | Compliance with legal obligations, Performance of a contract |
Maintaining a record of banned users to prevent further access to the Services | Legitimate interests |
Reporting illegal activity to relevant authorities and organisations | Legitimate interests, Task carried out in the public interest |
Preservation and sharing of personal data in legal proceedings | Legitimate interests |
Complying with applicable laws, rules, and regulations | Compliance with legal obligations, Legitimate interests |
Monitoring transactions, systems, and data for security and user safety | Legitimate interests, Task carried out in the public interest |
Protecting the rights and property of users and third parties | Legitimate interests |
Data analysis, system maintenance, reporting, and hosting for service improvement | Consent, Legitimate interests |
Possible sale, merger, acquisition, reorganisation, or restructuring exercise | Legitimate interests |
Processing personal data in connection with sponsorships, service providers, and professional advisers | Performance of a contract, Legitimate interests |
We collect your personal data from the following sources:
We share personal data with the following categories of third parties:
We may transfer your personal data to countries outside Australia, the UK, the European Economic Area (EEA), the United States of America, and Switzerland. These transfers are made in the following ways:
If you would like more information about the specific mechanisms used for transferring your personal data, please contact us using the contact details provided in Section 19 (assistance and contact information).
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 (assistance and contact information).
Your rights include:
Please note that we do not make solely automated decisions that have legal or similarly significant effects on individuals.
To exercise your rights regarding personal data, you can contact us using the contact details provided in Section 19 (assistance and contact information).
When submitting a request, please ensure that it contains sufficient information to allow us to confirm your identity and properly evaluate and respond to it. In some cases, we may need to request additional personal data to verify your identity, taking into consideration the sensitivity of your request. We may decline a privacy rights request if we are unable to verify your identity.
If a third party submits a request on your behalf, we will require proof that the third party has your permission to make the request.
You have certain choices and control over your personal data:
Please note that certain automated email notifications that are necessary to provide the Services or required by law cannot be opted out of.
We retain your personal data for as long as reasonably necessary to fulfil the purposes for which it was collected, as outlined in our privacy policy. The retention period may vary depending on the specific circumstances and legal requirements.
We generally retain personal data for a period of 6 months after the deletion or deactivation of your account on the website. However, we may retain personal data for longer periods for purposes such as compliance with legal obligations, protection of user and third-party rights, and responding to requests from authorities.
If you have questions about our privacy policy or how we process your personal data, you can contact our Data Protection Officer (“DPO”) or privacy specialists by submitting a ticket through your account or by emailing [email protected].
Residents of the States of California, Colorado, Connecticut, Nevada, Utah, and Virginia: These additional state-specific disclosures ("State Disclosures") supplement the information contained in our Privacy Policy by providing additional details about our personal data processing practices concerning individual residents of these states. Unless otherwise stated, all terms defined in the Privacy Policy retain the same meaning in these State Disclosures.
For the purposes of these State Disclosures, personal data does not include publicly available information or deidentified, aggregated, or anonymised information that cannot be associated with or linked to you.
No sales or targeted advertising
We do not sell or share personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual's activities across businesses or distinctly-branded websites, applications, or other services (referred to as "targeted advertising").
Sensitive information
While we may disclose sensitive information for business purposes as described below, we do not sell or share sensitive information for the purpose of targeted advertising.
The following personal data elements we collect, or our service providers collect, may be classified as "sensitive" under certain privacy laws ("sensitive information"), including:
We use this sensitive information for the purposes outlined in Section 11 of our Privacy Policy, to the extent necessary for the operation of our Services, to enter into and perform a contract with you, to comply with legal and regulatory requirements, to protect the safety of our users and third parties, or as otherwise permissible for our own internal purposes consistent with applicable laws.
De-identified information
We may receive or process personal data to create de-identified information that can no longer reasonably be used to infer information about or link to a particular individual or household. When maintaining de-identified information, we will use and maintain the information in de-identified form and will not attempt to re-identify the information except as required or permitted by applicable law.
Minors
Our Services are strictly intended for individuals who are 18 years of age or older. Individuals under 18 years of age are not permitted to use our Services. By using our Services, you represent that you are 18 years of age or older.
CALIFORNIA SPECIFIC DISCLOSURES
The following disclosures apply specifically to residents of the State of California:
Personal data collection
California law requires us to provide disclosures regarding the personal data we collect, based on the categories of personal data defined in California law. To fulfil this requirement, we have identified the relevant categories for the personal data described in more detail in Section 9 (categories of personal data) of our Privacy Policy:
We may disclose all of these categories of personal data for a business purpose to service providers or other third parties, as outlined in Section 13 (sharing your personal data) of our Privacy Policy.
Disclosure of personal data
As described in Section 13 of our Privacy Policy, we may disclose the identified categories of personal data to the following categories of third parties for various business purposes: our group and affiliated companies, service providers, professional advisers, business partners, other businesses as needed to provide our Services, and certain third parties with your consent or when required by law or legal process.
Sources of personal data
We collect personal data directly from you, from your browser or device when you interact with our Services, and from our business partners and affiliates, third parties you direct to share information with us, and other third-party providers. For more information, please refer to Section 12 (obtaining your personal data) of our Privacy Policy.
Purpose for collection
We collect personal data about you for the purposes outlined in Section 11 (how/why we use your personal data and lawful basis for processing) of our Privacy Policy.
Notice of financial incentives
Currently, we do not use any cross-site tracking technologies, and we do not sell or share personal data collected about you for cross-context behavioural advertising. We do not send emails for direct marketing purposes.
We offer a referral program for existing PlayHouse users, allowing them to introduce individuals interested in becoming users on our platform. Referring users receive referral payments based on the earnings of the referred users. The referral program is subject to our Terms of Service, and any referral payments are calculated and limited as described in the Referral Program Terms in our Terms of Service.
Any personal data associated with referring or referred users is processed in accordance with our Privacy Policy.
We have determined that the value of the referral program is reasonably related to the value of the personal data we process in connection with the program. We estimate the value of the personal data we receive and process by considering the expenses incurred in collecting and processing the data, as well as the expenses related to facilitating the referral program.
You may exercise your rights regarding your personal data as outlined in our Privacy Policy by submitting a ticket through your account or by emailing [email protected].
Last updated: July 2023