Mature Fans

Privacy & Policy

[COMPANY NAME]

Last updated: April 2, 2026

1. Introduction and Data Controller

[COMPANY NAME] ("we", "us", "our"), operator of the Mature Fans platform ("Platform"), is the data controller responsible for your personal data. We are incorporated under the laws of the Netherlands and process personal data in accordance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and applicable Dutch data protection law.

This Privacy Policy explains what personal data we collect, why we collect it, how we use it, who we share it with, and what rights you have in relation to it. Please read it carefully.

Data Controller contact details:

[COMPANY NAME]

[Company address — to be completed]

Email: privacy@maturefans.com

Website: maturefans.com

2. What Personal Data We Collect

We collect the following categories of personal data depending on how you use the Platform:

2.1 Account Registration Data

• Username and display name

• Email address

• Date of birth (for age verification)

• Password (stored in encrypted form)

• Account type (Fan or Creator)

2.2 Identity Verification Data (Creators only)

• Government-issued identification document (passport, national ID, or driving licence)

• Selfie photograph for identity matching

• Date of birth

• Full legal name

This data is processed for KYC (Know Your Customer) compliance and age verification purposes. We may use a third-party verification provider to process this data on our behalf.

2.3 Payment and Financial Data

• Payment method details (processed by [PAYMENT PROCESSOR] — we do not store full card numbers)

• Billing address

• Transaction history

• Payout details for Creators (bank account or payment method information)

2.4 Content and Activity Data

• Content you upload as a Creator (photos, videos, audio, text)

• Content you interact with as a Fan

• Subscription and purchase history

• Direct messages sent and received on the Platform

• Tips sent and received

• Comments and interactions

2.5 Model Release and Consent Documentation

For Creators uploading NSFW Content, we collect and store signed model release forms and associated identity and consent documentation for all individuals depicted in Content. This is retained for legal compliance purposes.

2.6 Technical and Usage Data

• IP address

• Browser type and version

• Operating system

• Device identifiers (for mobile access)

• Pages visited and time spent on the Platform

• Referring URLs

• Cookie data (see Section 9)

2.7 Communications Data

• Support requests and correspondence with our team

• Responses to surveys or feedback forms

• Reports submitted about Content or users

2.8 Third-Party Platform Data

If you connect a third-party account (such as X/Twitter) to the Platform for cross-posting purposes, we collect and store OAuth tokens necessary to perform authorized actions on your behalf. These tokens are stored securely and used solely for the purposes you have authorized.

3. Lawful Basis for Processing

We process your personal data on the following lawful bases under Article 6 GDPR:

Performance of a contract (Article 6(1)(b)): Processing necessary to provide the Platform and its services, including account management, subscription processing, Creator payouts, and Fan Locker access.

Legal obligation (Article 6(1)(c)): Processing required to comply with applicable law, including KYC/AML obligations (Dutch Wwft), age verification requirements, tax obligations, and content moderation duties under the DSA.

Legitimate interests (Article 6(1)(f)): Processing for fraud prevention, platform security, abuse detection, analytics to improve the Platform, and referral program administration — where our interests are not overridden by your rights.

Consent (Article 6(1)(a)): Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time.

Where we process special category data (such as biometric data used in identity verification), we rely on Article 9(2)(g) GDPR (substantial public interest — prevention of fraud and illegal content) and, where applicable, your explicit consent under Article 9(2)(a).

4. How We Use Your Personal Data

We use your personal data for the following purposes:

• Creating and managing your account;

• Verifying your identity and age (Creators and, where required, Fans);

• Processing payments, subscriptions, PPV purchases, tips, and Creator payouts;

• Providing access to Content and maintaining your Fan Locker;

• Enabling direct messaging between Fans and Creators;

• Processing cross-posting to connected third-party platforms where authorized;

• Detecting and preventing fraud, abuse, and illegal activity;

• Complying with legal obligations including content moderation, takedown requests, and law enforcement cooperation;

• Improving and developing the Platform through analytics and usage data;

• Sending service-related communications (account notices, policy updates, security alerts);

• Sending marketing communications where you have opted in;

• Administering the referral program;

• Responding to support requests and complaints.

5. Who We Share Your Data With

We do not sell your personal data to third parties. We may share your data with the following categories of recipients:

5.1 Payment Processors

We share payment-related data with [PAYMENT PROCESSOR] to process transactions. They act as an independent data controller for payment processing purposes and are subject to their own privacy policies.

5.2 Identity Verification Providers

We use a third-party KYC provider to verify Creator identities. This provider processes identification documents and selfies on our behalf under a data processing agreement.

5.3 Cloud and Hosting Providers

Your data is stored on secure servers provided by our hosting and infrastructure partners. These providers act as data processors under our instruction.

5.4 Analytics Providers

We use analytics tools to understand how the Platform is used. Where these involve third-party providers, we ensure appropriate data processing agreements are in place and, where possible, data is anonymized or pseudonymized.

5.5 Law Enforcement and Regulatory Authorities

We may disclose your data to law enforcement agencies, regulatory bodies, or courts where required by applicable law, a court order, or to protect the rights, safety, or property of the Company, our users, or the public. We will notify you of such disclosures where legally permissible.

5.6 Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business, your personal data may be transferred to the acquiring entity. We will notify you before your data is transferred and becomes subject to a different privacy policy.

5.7 Other Users

Certain information you make public on the Platform (such as your username, profile picture, and public Content) will be visible to other users. Private messages and non-public Content are not shared with other users except as part of the intended Creator Interaction.

6. International Data Transfers

The Platform is operated from the Netherlands. If we transfer your personal data outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place in accordance with Chapter V of the GDPR, including:

• Transfers to countries with an EU adequacy decision;

• Use of Standard Contractual Clauses (SCCs) approved by the European Commission;

• Other appropriate transfer mechanisms as required.

You may request details of the safeguards we have in place for international transfers by contacting privacy@maturefans.com.

7. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including to comply with legal obligations. The following retention periods apply:

• Account data — retained for the duration of your account and for up to 3 years after account deletion, unless a longer period is required by law;

• Transaction and financial records — retained for 7 years in accordance with Dutch tax and accounting law;

• Identity verification and model release documentation — retained for a minimum of 7 years from the date the associated Content was last available on the Platform, or from the date the Creator's account was closed, whichever is later. This retention is mandatory and cannot be waived or shortened, for the reasons explained in the note below.

Important note for Creators regarding identity and model release records: We are frequently asked by Creators and models whether they can invoke their GDPR right to erasure (Article 17) to have their identity documents or model release forms deleted. The answer is no — and this is not a choice we make, but a legal requirement. The retention of these records is a mandatory legal obligation that overrides the right to erasure under Article 17(3)(b) GDPR. Specifically, these records must be retained to comply with: (i) 18 U.S.C. § 2257, the US federal record-keeping law for producers of sexually explicit content, which requires age verification records to be maintained and available for inspection; (ii) the due diligence and Know Your Customer (KYC) requirements of our banking partners and payment processors, who are required under anti-money laundering regulations to verify that the platform maintains adequate age and identity verification for all content performers; and (iii) applicable EU content regulation obligations. These records may be audited by regulatory authorities, payment processors, or banks at any time. Deleting them would expose the Company to serious legal and financial consequences and would put the platform's ability to operate at risk. We understand this may feel intrusive, but it is a non-negotiable requirement of operating a legal adult content platform.

• Support correspondence — retained for up to 3 years;

• Technical/log data — retained for up to 12 months;

• Marketing consent records — retained until consent is withdrawn plus 1 year.

When data is no longer required, it is securely deleted or anonymized.

8. Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights in relation to your personal data:

Right of access (Article 15): You may request a copy of the personal data we hold about you.

Right to rectification (Article 16): You may request that we correct inaccurate or incomplete personal data.

Right to erasure (Article 17): You may request that we delete your personal data. We will honour this request where we have no overriding legal obligation to retain the data. However, please note that certain data cannot be erased regardless of this request, specifically: identity verification documents, model release forms, and associated age and consent records. Retention of these records is a mandatory legal obligation under 18 U.S.C. § 2257, EU content regulation law, and the KYC/AML requirements of our banking and payment processing partners. The right to erasure under Article 17 GDPR does not apply where processing is necessary for compliance with a legal obligation (Article 17(3)(b)). This applies even if you close your Creator account or remove your Content from the Platform.

Right to restriction of processing (Article 18): You may request that we restrict the processing of your data in certain circumstances.

Right to data portability (Article 20): You may request a copy of your data in a structured, machine-readable format where processing is based on consent or contract.

Right to object (Article 21): You may object to processing based on legitimate interests or for direct marketing purposes.

Right to withdraw consent: Where we rely on consent as a lawful basis, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at privacy@maturefans.com. We will respond within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl, or the supervisory authority in your EU country of residence.

9. Cookies

We use cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device that help us provide and improve the Platform.

We use the following types of cookies:

• Strictly necessary cookies — required for the Platform to function. These cannot be disabled.

• Functional cookies — remember your preferences and settings;

• Analytics cookies — help us understand how the Platform is used (e.g. Google Analytics);

• Marketing cookies — used to serve relevant advertising where applicable.

You can manage your cookie preferences through our cookie consent tool when you first visit the Platform, or at any time through your browser settings. Disabling certain cookies may affect the functionality of the Platform.

For full details of the cookies we use, please see our Cookie Policy.

10. Mobile Devices

If you access the Platform via a mobile device or app, we may collect additional data including:

• Device identifiers (device ID, model, manufacturer);

• Operating system and version;

• Push notification tokens (if you opt in to notifications);

• General location data derived from IP address.

We do not collect precise GPS location data. Push notifications can be disabled at any time through your device settings.

11. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or disclosure. These include encryption of data in transit and at rest, access controls, and regular security assessments.

However, no method of transmission over the internet is completely secure. You are responsible for keeping your account credentials confidential. If you believe your account has been compromised, please contact us immediately at support@maturefans.com and change your password.

12. Children

The Platform is strictly for adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that we have collected data from a minor, we will delete it immediately. If you believe a minor has registered on the Platform, please contact us at legal@maturefans.com.

13. Third-Party Websites

The Platform may contain links to third-party websites. This Privacy Policy applies only to the Mature Fans Platform. We are not responsible for the privacy practices of third-party sites and encourage you to review their privacy policies before providing any personal data.

14. Do Not Track

Some browsers transmit Do Not Track (DNT) signals. The Platform does not currently alter its data collection practices in response to DNT signals, as there is no universally accepted standard for how platforms should respond to these signals. You can manage tracking preferences through our cookie consent tool.

15. California Users — CCPA

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA). [COMPANY NAME] does not sell personal information to third parties. California residents may request to know what personal information we collect, request deletion of their personal information, and opt out of any sale of personal information (though no such sale takes place). To exercise these rights, contact privacy@maturefans.com. We will not discriminate against you for exercising your CCPA rights.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or by a prominent notice on the Platform before the changes take effect. The date at the top of this Policy reflects when it was last updated. We encourage you to review this Policy periodically.

17. Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or our data practices, please contact:

[COMPANY NAME]

[Company address — to be completed]

Email: privacy@maturefans.com

Website: maturefans.com

Dutch Data Protection Authority: autoriteitpersoonsgegevens.nl

This Privacy Policy forms part of the Mature Fans Terms of Service. In the event of any conflict between this Policy and the Terms of Service, the Terms of Service shall prevail.