Privacy Policy

Privacy Policy

Introduction

Data Controller

Scope of this Privacy Policy

Personal Data We Collect

How We Use Your Personal Data

Legal Bases for Processing (GDPR)

Sharing Your Personal Data

International Data Transfers

Data Retention

Your Privacy Rights

Cookies & Similar Technologies

Security

Children's Privacy

Third-Party Services

Automated Decision-Making & Artificial Intelligence (AI)

Changes to this Privacy Policy

Contact Information

Privacy Policy

1. Introduction

Welcome to Spopyyou, operated by sebavision OÜ ("Spopyyou", "we", "our" or "us").

We respect your privacy and are committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, share and protect your personal data when you access or use:

the Spopyyou website;

mobile applications;

Creator Services;

Host Services;

Events;

Communities;

messaging features;

Premium Services;

Coins;

payment services;

identity verification;

customer support;

and all other services provided by Spopyyou (collectively, the "Platform").

This Privacy Policy should be read together with our:

Terms & Conditions;

Cookie Policy;

Community Guidelines;

Creator Terms;

Host Terms;

Refund Policy;

Restricted Content Policy;

and any additional policies published on the Platform.

By using the Platform, you acknowledge that your personal data may be processed as described in this Privacy Policy.

Nothing in this Privacy Policy limits any mandatory rights available to you under applicable data protection laws.

2. Data Controller

Unless otherwise stated, the controller responsible for the processing of your personal data is:

sebavision OÜ

Harju maakond, Tallinn
Kesklinna linnaosa
Tartu mnt 67/1-13b
10115 Tallinn
Estonia

Email: privacy@spopyyou.com

Website: https://www.spopyyou.com

Where required by applicable law, Spopyyou may appoint:

an EU representative;

a Data Protection Officer (DPO);

local privacy representatives;

or other authorized representatives.

Their contact details will be published on the Platform where applicable.

3. Scope of this Privacy Policy

This Privacy Policy applies to the processing of personal data relating to:

visitors of the Platform;

registered users;

Premium members;

Premium+ members;

Founder members;

Creators;

Hosts;

Venue Managers;

Enterprise customers;

applicants for verification;

event participants;

customer support users;

business partners where applicable.

This Privacy Policy applies whenever you:

create an account;

browse the Platform;

communicate with other users;

publish content;

purchase memberships;

purchase Coins;

subscribe to Creators;

organize or attend events;

participate in communities;

contact customer support;

complete identity verification;

interact with Spopyyou through other lawful means.

This Privacy Policy does not apply to:

third-party websites;

third-party applications;

third-party payment providers;

external services not controlled by Spopyyou.

Those services are governed by their own privacy policies.

Deine Struktur ist tatsächlich besser und entspricht eher dem Aufbau der Datenschutzerklärungen großer Plattformen wie Meta, Discord oder Airbnb. Ich würde sie so übernehmen.

4. Personal Data We Collect

Depending on how you use the Platform, Spopyyou may collect the following categories of personal data.

4.1 Information You Provide

You may voluntarily provide personal data when you:

create an account;

complete your profile;

communicate with other users;

contact customer support;

purchase memberships or Coins;

subscribe to Creators;

create or join events;

apply as a Creator or Host;

participate in surveys or promotions;

submit reports or appeals;

otherwise interact with the Platform.

Providing certain information is necessary to access specific features or services. Other information is optional and may be provided at your discretion.

4.2 Account Information

When creating or maintaining an account, we may collect:

first name;

last name;

username;

display name;

email address;

encrypted password;

date of birth;

country of residence;

preferred language;

account settings;

membership status;

verification status;

account creation and login timestamps.

4.3 Profile Information

You may choose to provide profile information including:

profile photo;

biography;

interests;

hobbies;

languages spoken;

occupation;

education;

relationship preferences;

community preferences;

event preferences;

Creator or Host profile details;

social media links;

other optional profile information.

You control the information you choose to display, subject to the Platform's privacy settings and Community Guidelines.

4.4 Identity Verification (Veriff)

Where identity or age verification is required, Spopyyou or its verification provider (currently Veriff) may process:

legal name;

date of birth;

nationality;

government-issued identification;

facial image;

liveness verification;

verification status;

verification reference number;

verification timestamps.

Identity verification is used to:

verify age;

verify identity;

prevent fraud;

comply with legal obligations;

satisfy payment-provider requirements;

enable access to certain Platform features.

Spopyyou does not receive or retain more identity verification data than necessary for the purposes described in this Privacy Policy.

4.5 Payment Information

When purchasing memberships, Coins, event tickets or other paid services, payment-related information may be processed, including:

payment method;

billing country;

billing currency;

transaction identifier;

subscription status;

invoices;

payment confirmations;

refund information;

chargeback information.

Payment card information is processed by certified payment providers, such as Stripe and CCBill. Spopyyou does not store complete payment card numbers or card security codes.

4.6 Creator & Host Information

Creators and Hosts may provide additional information necessary to use Creator or Host Services, including:

business or professional name;

payout information;

tax information where required;

bank or payout account details;

Creator profile information;

Host profile information;

venue information;

business registration details where applicable;

verification information;

account statistics relating to Creator or Host activities.

4.7 Event Information

When creating, managing or participating in events, we may process:

event registrations;

attendance status;

ticket purchases;

QR Check-in information;

event invitations;

waiting list status;

event preferences;

event reviews;

event-related communications;

Host and participant interactions.

4.8 Messaging & Communications

When using communication features, we may process:

private messages;

voice messages;

media shared through the Platform;

customer support communications;

abuse reports;

appeals;

feedback;

system notifications;

communication preferences.

Communications may be processed where necessary to provide the service, investigate reports, prevent fraud, protect users or comply with applicable law.

4.9 Technical & Device Information

We automatically collect certain technical information, including:

IP address;

browser type;

operating system;

device type;

device identifiers;

language settings;

time zone;

log files;

crash reports;

diagnostic information;

security information;

session identifiers.

This information helps us operate, secure and improve the Platform.

4.10 Usage Data

We collect information about how the Platform is used, including:

pages viewed;

searches;

clicks;

feature usage;

Creator subscriptions;

Coins transactions;

event participation;

purchases;

interactions with content;

session duration;

referral information;

preferences and settings.

Usage data helps us improve the functionality, performance and security of the Platform.

4.11 Location Data

Where permitted by law and enabled by you, Spopyyou may process location information, including:

approximate location based on your IP address;

device location;

event location;

venue location;

location shared by you through the Platform.

Location information is used only where necessary to provide location-based features, improve user experience, facilitate event discovery or comply with applicable legal requirements.

You may manage your location permissions through your device settings or the Platform, where available.

Deine Gliederung ist sehr gut. Ich würde sie genau so übernehmen. Nachfolgend ist Section 5 in einem professionellen Stil formuliert.

5. How We Use Your Personal Data

Spopyyou processes personal data only where necessary to provide, operate, improve and protect the Platform, to comply with legal obligations and to provide the services requested by users.

The purposes for which we process your personal data include the following.

5.1 Providing the Platform

We use your personal data to provide and operate the Platform, including to:

create and maintain your account;

authenticate your identity;

provide access to Platform features;

enable Communities, Events and Creator Services;

display your profile in accordance with your privacy settings;

synchronize your account across supported devices;

provide multilingual functionality;

operate Premium and Premium+ features.

5.2 Account Management

We process your personal data to:

verify your email address;

manage your account settings;

maintain your profile;

manage account security;

process account recovery requests;

respond to account-related inquiries;

administer verification status;

enable account deletion where requested.

5.3 Memberships

We process personal data relating to memberships in order to:

activate memberships;

manage subscriptions;

process renewals;

process cancellations;

apply Founder benefits;

provide Premium and Premium+ features;

administer membership benefits;

prevent membership abuse.

5.4 Creator Services

Where you use Creator Services, we process personal data to:

create Creator profiles;

manage subscriptions;

process Pay-Per-View purchases;

process tips;

calculate Creator earnings;

process payouts;

verify Creator eligibility;

comply with payment-provider requirements;

prevent fraud and abuse.

5.5 Events & Hosts

We process personal data relating to events in order to:

create and publish events;

manage event registrations;

administer ticket purchases;

facilitate QR Check-in;

manage invitations and waiting lists;

verify attendance;

support Hosts and Venue Managers;

improve event management.

5.6 Payments & Coins

We process payment-related information to:

process purchases;

manage memberships;

process Coins purchases;

administer refunds where applicable;

investigate chargebacks;

prevent payment fraud;

comply with financial and tax obligations;

maintain transaction records.

Payment transactions may be processed by independent payment providers, including Stripe and CCBill.

5.7 Customer Support

We process personal data to:

respond to inquiries;

resolve technical issues;

investigate reports;

process appeals;

improve customer service;

provide account assistance;

communicate with users regarding their requests.

Support communications may be retained where reasonably necessary for quality assurance, security and legal compliance.

5.8 Safety & Fraud Prevention

We process personal data to help maintain a safe and trustworthy Platform, including to:

verify user identity;

prevent fraud;

detect fake accounts;

identify suspicious activity;

investigate reports;

enforce our Terms and Community Guidelines;

protect users from abuse;

prevent unauthorized access;

comply with legal and regulatory obligations.

5.9 AI Moderation

Where appropriate, Spopyyou may use artificial intelligence and automated technologies to assist in:

content moderation;

spam detection;

fraud detection;

fake profile detection;

image analysis;

detection of prohibited content;

safety monitoring;

risk assessment;

platform security.

Automated systems support, but do not necessarily replace, human review.

Where required by applicable law, users may request a review of significant decisions made with the assistance of automated systems.

5.10 Platform Improvements

We use personal data to improve the Platform by:

analyzing usage trends;

measuring feature performance;

identifying technical issues;

improving user experience;

optimizing security;

developing new features;

testing platform improvements;

generating aggregated and anonymized statistics.

Where possible, analytics are performed using aggregated or anonymized data.

5.11 Marketing & Communications

Where permitted by applicable law, we may use personal data to:

send service-related notifications;

communicate important account information;

provide membership information;

inform users about new Platform features;

send promotional communications;

conduct surveys;

invite users to participate in research.

Where consent is required, users may withdraw their consent at any time.

Users may unsubscribe from marketing communications through the Platform or the unsubscribe link included in the communication.

5.12 Legal Compliance

We process personal data where necessary to:

comply with applicable laws;

satisfy regulatory obligations;

respond to lawful requests from competent authorities;

comply with court orders;

enforce our Terms;

establish, exercise or defend legal claims;

comply with tax, accounting and financial obligations;

protect the rights, property and safety of Spopyyou, our users and third parties.

Personal data will be processed only for lawful purposes and only to the extent necessary to fulfil the relevant legal obligation.

Deine Gliederung ist sehr gut und entspricht der DSGVO (Art. 6 GDPR). Ich würde sie genau so übernehmen.

6. Legal Bases for Processing (GDPR)

Where the General Data Protection Regulation (EU) 2016/679 ("GDPR") applies, Spopyyou processes personal data only where a valid legal basis exists.

Depending on the circumstances, one or more of the following legal bases may apply.

6.1 Contract Performance

We process personal data where necessary to perform a contract with you or to take steps at your request before entering into a contract.

This includes processing necessary to:

create and maintain your account;

provide access to the Platform;

manage memberships and subscriptions;

process payments and Coins purchases;

provide Creator and Host Services;

manage events and registrations;

verify account access;

provide customer support;

perform other services requested by you.

Without this processing, certain Platform features may not be available.

6.2 Legal Obligations

We process personal data where necessary to comply with applicable legal or regulatory obligations.

This may include processing required to:

comply with tax and accounting obligations;

comply with anti-money laundering and fraud prevention requirements;

comply with payment provider requirements;

comply with identity verification requirements;

respond to lawful requests from courts or public authorities;

establish, exercise or defend legal claims;

comply with applicable consumer protection laws;

comply with other legal obligations.

6.3 Legitimate Interests

We may process personal data where necessary for our legitimate interests, provided that those interests are not overridden by your fundamental rights and freedoms.

Our legitimate interests include:

operating and improving the Platform;

maintaining Platform security;

preventing fraud and abuse;

protecting users;

detecting fake accounts;

enforcing our Terms and Community Guidelines;

improving customer support;

developing new features;

analyzing Platform performance;

protecting our legal rights;

maintaining the stability and integrity of the Platform.

Where required, we carry out an appropriate balancing test before relying on this legal basis.

6.4 Consent

Where required by applicable law, we process personal data based on your consent.

Consent may be requested for activities such as:

marketing communications;

non-essential cookies;

location services;

optional profile features;

participation in surveys;

optional promotional activities;

other processing where consent is required by law.

You may withdraw your consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

6.5 Protection of Vital Interests

In limited circumstances, we may process personal data where necessary to protect the vital interests of you or another natural person.

This legal basis may apply, for example, where processing is necessary to:

protect the life, health or safety of users;

respond to emergencies;

prevent imminent harm;

comply with urgent legal or public safety requirements.

Such processing will occur only where permitted by applicable law and only to the extent necessary for the relevant purpose.

7. Sharing Your Personal Data

Spopyyou does not sell your personal data.

We share personal data only where necessary to provide the Platform, comply with legal obligations, protect users, prevent fraud or where you have given your consent.

Where appropriate, third parties process personal data on our behalf under contractual agreements requiring them to protect your information in accordance with applicable data protection laws.

7.1 Payment Providers

To process purchases, memberships, subscriptions, Coins, Creator transactions and other payments, we may share relevant personal data with our payment providers.

Depending on the service used, this may include providers such as:

Stripe;

CCBill;

banks;

payment processors;

payment service providers.

Information shared may include:

name;

billing information;

transaction details;

payment amount;

payment status;

country;

currency;

fraud prevention information.

Payment providers process personal data in accordance with their own privacy policies and applicable legal requirements.

7.2 Identity Verification Providers

Where identity or age verification is required, we may share relevant information with identity verification providers.

This may include providers such as:

Veriff;

other approved identity verification providers.

Information shared may include:

legal name;

date of birth;

government-issued identification;

facial image;

liveness verification;

verification status;

verification reference number.

Identity verification providers process personal data solely for identity verification, fraud prevention and legal compliance purposes.

7.3 Cloud & Infrastructure Providers

To operate and secure the Platform, we use trusted cloud and infrastructure providers.

These may include providers such as:

Amazon Web Services (AWS);

Cloudflare;

content delivery providers;

database providers;

hosting providers;

backup providers.

These providers may process personal data only to the extent necessary to host, secure and maintain the Platform.

7.4 Analytics & Technical Providers

We may use trusted analytics and technical service providers to help us understand how the Platform is used and to improve its functionality.

These providers may process information relating to:

Platform performance;

technical diagnostics;

crash reports;

security monitoring;

fraud detection;

aggregated usage statistics.

Where possible, analytics are performed using aggregated, anonymized or pseudonymized data.

7.5 Customer Support Providers

To provide customer support, we may share relevant information with service providers assisting us with:

customer support;

help desk services;

email communications;

technical assistance;

abuse investigations;

fraud investigations.

Only the information necessary to provide the requested support or service is shared.

7.6 Legal Authorities

We may disclose personal data where required or permitted by applicable law, including where necessary to:

comply with legal obligations;

comply with court orders;

respond to lawful requests from competent authorities;

protect the rights, safety or property of Spopyyou, our users or others;

investigate fraud or illegal activity;

establish, exercise or defend legal claims.

We will disclose only the information reasonably necessary for the relevant legal purpose.

7.7 Business Transfers

If Spopyyou or sebavision OÜ is involved in a merger, acquisition, investment, financing, corporate restructuring, sale of assets or similar business transaction, personal data may be transferred as part of that transaction.

Where required by applicable law, users will be informed before such a transfer becomes effective.

Any successor or acquiring entity will be required to process personal data in accordance with this Privacy Policy or a substantially equivalent level of protection, unless applicable law requires otherwise.

7.8 Professional Advisers

We may share personal data, where necessary, with our professional advisers, including:

lawyers;

accountants;

auditors;

insurers;

compliance advisers.

Such disclosures are made only where necessary for legal, financial, regulatory or business purposes and are subject to appropriate confidentiality obligations.

8. International Data Transfers

Spopyyou operates internationally and may transfer or allow access to personal data across national borders where necessary to provide the Platform and its services.

Where personal data is transferred outside the European Economic Area ("EEA"), the United Kingdom or other jurisdictions with equivalent data protection standards, Spopyyou will ensure that appropriate safeguards are in place in accordance with applicable data protection laws.

Such safeguards may include:

an adequacy decision issued by the European Commission;

the European Commission's Standard Contractual Clauses (SCCs);

approved certification mechanisms;

binding corporate rules (where applicable);

other lawful transfer mechanisms recognized under applicable law.

We take reasonable measures to ensure that any recipient of personal data provides an adequate level of protection consistent with this Privacy Policy and applicable data protection laws.

Where required by applicable law, you may request further information regarding the safeguards applied to international data transfers by contacting us using the details provided in this Privacy Policy.

9. Data Retention

Spopyyou retains personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce our Terms and protect the security and integrity of the Platform.

The retention period depends on the type of personal data, the purpose of processing and applicable legal or regulatory requirements.

Personal data may be retained where necessary to:

provide the Platform and its services;

maintain user accounts;

manage memberships and subscriptions;

process payments and Creator payouts;

administer events and Host Services;

investigate fraud, abuse or security incidents;

comply with tax, accounting and legal obligations;

establish, exercise or defend legal claims;

enforce our Terms and Community Guidelines.

When personal data is no longer required, it will be securely deleted, anonymized or otherwise disposed of in accordance with applicable law and our internal data retention procedures.

Where users request deletion of their account or personal data, we will delete or anonymize the relevant information unless we are required or permitted by law to retain certain data.

Certain information may continue to be retained for a limited period where necessary to:

comply with legal obligations;

prevent fraud;

resolve disputes;

enforce our legal rights;

protect the safety and security of the Platform;

comply with requests from competent authorities.

10. Your Privacy Rights

Where the GDPR or other applicable data protection laws apply, you may have the following rights regarding your personal data.

The availability of these rights may depend on your country of residence and the applicable legal requirements.

10.1 Right of Access

You have the right to request confirmation as to whether Spopyyou processes your personal data.

Where applicable, you may also request access to your personal data and receive information regarding:

the categories of personal data processed;

the purposes of processing;

the recipients or categories of recipients;

the retention period;

your privacy rights;

international data transfers;

the source of the personal data where it was not collected directly from you.

Where required by applicable law, you may also request a copy of your personal data.

10.2 Right to Rectification

You have the right to request that inaccurate or incomplete personal data be corrected or updated without undue delay.

Where available, you may also update certain personal information directly through your account settings.

10.3 Right to Erasure

You may request the deletion of your personal data where permitted by applicable law.

This right may apply where:

the personal data is no longer necessary;

you withdraw consent where consent is the legal basis;

you successfully object to processing;

the personal data has been processed unlawfully;

deletion is required by applicable law.

This right is not absolute.

Spopyyou may retain certain personal data where required or permitted by law, including for:

legal compliance;

fraud prevention;

dispute resolution;

enforcement of our Terms;

establishment, exercise or defence of legal claims.

10.4 Right to Restrict Processing

You may request that the processing of your personal data be restricted where permitted by applicable law.

Restriction may apply where:

the accuracy of the personal data is contested;

the processing is unlawful but you oppose deletion;

the personal data is no longer required by Spopyyou but is required for legal claims;

you have objected to processing and verification is pending.

During a period of restriction, personal data may continue to be stored where permitted by law.

10.5 Right to Data Portability

Where processing is based on your consent or on a contract and carried out by automated means, you may request to receive your personal data in a structured, commonly used and machine-readable format.

Where technically feasible and legally applicable, you may also request that your personal data be transferred directly to another data controller.

10.6 Right to Object

You may object to the processing of your personal data where processing is based on legitimate interests.

You also have the right to object at any time to the processing of your personal data for direct marketing purposes.

Where a valid objection is received, Spopyyou will cease processing the relevant personal data unless we demonstrate compelling legitimate grounds or another lawful basis for continuing the processing.

10.7 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Where available, consent preferences may be managed through your account settings, cookie settings or by contacting Spopyyou.

10.8 Right to Lodge a Complaint

If you believe that the processing of your personal data violates applicable data protection laws, you have the right to lodge a complaint with the competent data protection authority in your country of residence, place of work or the place of the alleged infringement.

You may also contact Spopyyou directly, and we will make reasonable efforts to address your concerns.

10.9 Exercising Your Rights

You may exercise your privacy rights at any time by contacting Spopyyou using the contact details provided in this Privacy Policy.

Where available, you may also exercise certain rights directly through your account settings on the Platform.

To protect your privacy and the security of your personal data, we may request additional information to verify your identity before processing your request.

We will respond to your request within the time limits required by applicable data protection laws. In certain circumstances, we may extend this period where permitted by law, taking into account the complexity and number of requests. Where applicable, we will inform you of any such extension and the reasons for it.

The exercise of your rights may be subject to legal exceptions or limitations under applicable law.

Where a request is manifestly unfounded or excessive, particularly because of its repetitive nature, Spopyyou reserves the right, to the extent permitted by applicable law, to refuse the request or charge a reasonable administrative fee.

11. Cookies & Similar Technologies

Spopyyou uses cookies and similar technologies to operate, secure and improve the Platform.

These technologies may include:

cookies;

local storage;

session storage;

pixels;

software development kits (SDKs);

web beacons;

similar tracking technologies.

Some cookies are necessary for the operation of the Platform, while others are used only with your consent where required by applicable law.

Further information, including details about individual cookies, retention periods and providers, is available in our Cookie Policy and Cookie Preferences.

11.1 Essential Cookies

Essential cookies are necessary for the proper operation of the Platform and cannot be disabled through our Cookie Preferences.

These cookies may be used to:

authenticate users;

maintain secure login sessions;

protect user accounts;

enable essential Platform functionality;

remember security settings;

prevent fraud and abuse;

balance network traffic;

maintain system stability.

Because these cookies are necessary for the operation of the Platform, they do not require consent where permitted by applicable law.

11.2 Functional Cookies

Functional cookies help improve your experience by remembering your preferences and providing enhanced functionality.

These cookies may be used to remember:

language preferences;

region;

display settings;

accessibility preferences;

notification settings;

account preferences;

other optional user settings.

Where required by applicable law, functional cookies are used only with your consent.

11.3 Analytics Cookies

Analytics cookies help us understand how the Platform is used and enable us to improve its performance and user experience.

These cookies may collect information such as:

pages visited;

feature usage;

session duration;

navigation patterns;

device information;

performance metrics;

error reports.

Where possible, analytics data is aggregated, anonymized or pseudonymized.

Analytics cookies are used only where permitted by applicable law and, where required, only with your consent.

11.4 Marketing Cookies

Marketing cookies may be used to measure the effectiveness of campaigns and to provide more relevant communications and advertisements.

These cookies may be used to:

measure marketing performance;

prevent repetitive advertisements;

personalize promotional content;

analyze campaign effectiveness;

attribute referrals;

improve marketing communications.

Spopyyou does not sell your personal data.

Marketing cookies are used only with your consent where required by applicable law.

You may withdraw your consent at any time.

11.5 Managing Cookie Preferences

You can manage your cookie preferences at any time through the Cookie Preferences available on the Platform.

Subject to applicable law, you may:

accept all cookies;

reject non-essential cookies;

customize your cookie preferences;

withdraw previously given consent;

change your preferences at any time.

You may also control cookies through your browser or device settings. Please note that disabling certain cookies may affect the availability or functionality of parts of the Platform.

Changes to your cookie preferences do not affect the lawfulness of processing carried out before your preferences were updated.

12. Security

Spopyyou is committed to protecting the confidentiality, integrity and availability of personal data.

We implement appropriate technical and organisational measures designed to protect personal data against unauthorized access, accidental loss, destruction, alteration, disclosure or other unlawful processing.

While we strive to maintain a high level of security, no internet-based service or electronic storage system can be guaranteed to be completely secure.

12.1 Technical Measures

Spopyyou implements appropriate technical safeguards designed to protect personal data, which may include:

encryption of data in transit using secure communication protocols;

encryption of sensitive data at rest where appropriate;

secure authentication mechanisms;

role-based access controls;

multi-factor authentication for administrative access where appropriate;

security monitoring and logging;

intrusion detection and prevention measures;

regular software updates and security patches;

backup and disaster recovery procedures;

vulnerability assessments and security testing.

Technical measures are reviewed and updated where reasonably necessary to maintain an appropriate level of security.

12.2 Organisational Measures

In addition to technical safeguards, Spopyyou maintains organisational measures to protect personal data, including:

restricting access to personal data on a need-to-know basis;

confidentiality obligations for employees and authorized personnel;

internal security policies and procedures;

staff training on data protection and information security;

procedures for responding to security incidents;

regular reviews of security practices;

oversight of third-party service providers processing personal data on our behalf.

Where third-party processors are engaged, they are required to implement appropriate safeguards and comply with applicable data protection laws.

12.3 Account Security

Users are responsible for maintaining the security of their accounts.

Users should:

choose a strong and unique password;

keep login credentials confidential;

enable multi-factor authentication where available;

protect their devices against unauthorized access;

promptly notify Spopyyou of any suspected unauthorized access or security incident affecting their account.

Spopyyou will never ask users to disclose their password through email or unsolicited communications.

If we become aware of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, we will respond in accordance with applicable law, including notification to competent authorities and affected users where required.

13. Children's Privacy

Spopyyou is intended exclusively for individuals who are at least 18 years of age.

We do not knowingly collect, process or store personal data from anyone under the age of 18.

Users must not create an account or use the Platform if they are under 18 years of age.

Where identity or age verification is required, Spopyyou may use verification procedures to confirm that users meet the minimum age requirement.

If we become aware that personal data has been collected from a person under the age of 18 in violation of this Privacy Policy or our Terms, we will take appropriate steps to:

suspend or terminate the account;

remove the associated personal data, unless retention is required by applicable law;

restrict access to the Platform;

take any additional measures required by applicable law.

If you believe that a person under the age of 18 has created an account or provided personal data to Spopyyou, please contact us using the contact details provided in this Privacy Policy so that we can investigate and take appropriate action.

14. Third-Party Services

To provide, operate, secure and improve the Platform, Spopyyou works with trusted third-party service providers.

These providers process personal data only where necessary to perform services on our behalf or to provide services requested by you.

Each provider processes personal data in accordance with applicable data protection laws and its own privacy policy.

14.1 Stripe

Spopyyou may use Stripe to process eligible payments, including memberships, subscriptions, event tickets, Coins purchases and other supported transactions.

Stripe may process personal data including:

payment information;

billing information;

transaction details;

payment status;

fraud prevention information.

Stripe acts as an independent payment service provider and processes personal data in accordance with its own Privacy Policy and applicable legal requirements.

14.2 CCBill

For certain services, including eligible Creator Services and restricted content where legally permitted, Spopyyou may use CCBill as a payment processor.

CCBill may process personal data including:

payment information;

billing information;

transaction records;

payment status;

fraud prevention information;

chargeback information.

CCBill processes personal data independently in accordance with its own Privacy Policy and applicable payment regulations.

14.3 Veriff

Spopyyou may use Veriff or another approved identity verification provider to verify user identity and age.

Verification may include the processing of:

identity documents;

facial images;

liveness verification;

verification status;

verification reference information.

Identity verification helps us:

verify eligibility;

prevent fraud;

comply with legal obligations;

satisfy payment provider requirements;

maintain Platform safety.

14.4 Amazon Web Services (AWS)

Spopyyou uses Amazon Web Services (AWS) and related cloud infrastructure services to host, operate and secure the Platform.

AWS may process personal data where necessary to provide:

cloud hosting;

databases;

file storage;

backups;

infrastructure services;

security monitoring;

system availability.

14.5 Map Services

Where location-based features are available, Spopyyou may use third-party mapping services.

These services may support:

event locations;

venue locations;

maps;

navigation;

nearby events;

other location-based functionality.

Location information is processed only where necessary to provide these services or where you have granted the required permissions.

14.6 Other Service Providers

Spopyyou may engage additional trusted service providers to support the operation of the Platform.

These providers may assist with:

customer support;

email delivery;

security monitoring;

fraud prevention;

analytics;

content delivery;

communications;

platform performance;

legal compliance;

other operational services.

We require our service providers to process personal data only for authorized purposes, implement appropriate security measures and comply with applicable data protection laws.

Spopyyou remains committed to ensuring that all third-party providers handling personal data maintain an appropriate level of privacy and security consistent with this Privacy Policy.

15. Automated Decision-Making & Artificial Intelligence (AI)

Spopyyou may use artificial intelligence ("AI"), machine learning and other automated technologies to support the operation, security and integrity of the Platform.

AI systems are designed to assist our teams by improving efficiency, detecting suspicious activity and helping to protect users. Automated technologies support, but do not necessarily replace, human review.

Where required by applicable law, Spopyyou implements appropriate safeguards for users affected by automated processing.

15.1 AI-Assisted Moderation

Spopyyou may use AI-assisted systems to help identify content or behaviour that may violate our Terms, Community Guidelines or applicable law.

AI-assisted moderation may be used to detect, for example:

spam;

fake accounts;

impersonation;

fraudulent activity;

prohibited content;

abusive behaviour;

hate speech;

illegal content;

repeated policy violations;

suspicious account activity.

AI-generated assessments may be reviewed by authorized personnel before significant enforcement actions are taken, where appropriate.

15.2 Fraud Detection

To protect users, Creators, Hosts and the Platform, Spopyyou may use automated technologies to detect and prevent fraud and other security risks.

This may include identifying:

suspicious login activity;

unusual payment activity;

account takeover attempts;

fake identities;

chargeback abuse;

automated bots;

multiple accounts created in violation of our Terms;

other activities that may threaten the security or integrity of the Platform.

Automated systems help us reduce fraud and improve Platform security but are used together with additional security measures and, where appropriate, human review.

15.3 User Rights

Where automated processing is used in a manner that is subject to applicable data protection laws, users may have certain rights, including the right to:

request further information about the processing;

request human review where required by applicable law;

express their point of view;

challenge or appeal certain decisions;

exercise other rights available under applicable data protection laws.

Requests relating to automated processing may be submitted using the contact details provided in this Privacy Policy.

16. Changes to this Privacy Policy

Spopyyou may update or modify this Privacy Policy from time to time where reasonably necessary, including to:

comply with applicable laws or regulations;

reflect changes to the Platform or its services;

introduce new features or functionality;

improve our privacy and security practices;

reflect changes to third-party service providers;

address operational or technical requirements.

The most current version of this Privacy Policy will always be available on the Platform and will indicate its Effective Date and Last Updated date.

Where changes materially affect the way we process your personal data, we will provide appropriate notice as required by applicable law. Such notice may be provided through the Platform, by email or by other appropriate means.

Your continued use of the Platform after the updated Privacy Policy becomes effective constitutes your acknowledgment of the revised Privacy Policy, to the extent permitted by applicable law.

Nothing in this Section limits any rights you may have under applicable data protection laws.

17. Contact Information

If you have any questions about this Privacy Policy or how Spopyyou processes your personal data, you may contact us using the details below.

Data Controller

sebavision OÜ

Sepapaja tn 6

15551 Tallinn

Estonia

Website: https://www.spopyyou.com

General Support: support@spopyyou.com

Privacy Contact: privacy@spopyyou.com

Where required by applicable law, Spopyyou may appoint a Data Protection Officer (DPO) or another designated privacy contact. If appointed, the relevant contact details will be published on the Platform.

We will make reasonable efforts to respond to privacy-related requests within the time limits required by applicable data protection laws.