Privacy Policy

This Privacy Policy explains how Walker Capital Management LLC, doing business as FansXO (“FansXO,” “we,” or “us”), collects, uses, shares, and protects information when you use our website, mobile applications, and services (the “Service”).

FansXO is an adult-only platform. We do not knowingly collect information from anyone under 18. See § 7 below.

1. Information We Collect

Information you provide

• Account information. Email address, username, password (hashed), display name, and profile details.
• Verification information. Fans complete a brief facial age estimation; creators submit a government-issued ID, a live selfie, and related metadata. This information is collected and processed by our verification provider, currently Yoti Limited. We retain only the minimum result data (pass/fail, estimated age for fan AE, document type, and the redacted document image and selfie required by 18 U.S.C. § 2257 for creators) needed for compliance.
• Payment information. Token purchases are processed by Ramp Network, our cryptocurrency on-ramp provider. We do not store payment card data; we retain only the Ramp transaction ID, the on-chain transaction hash, and the amount in USDC and USD.
• Payout information. Crypto wallet addresses (creators), tax forms (W-9 / W-8BEN where applicable), and payout history.
• Content. Messages, photos, videos, and other material you submit through the Service.
• Communications. Emails, chat transcripts with support, and bug reports.

Information collected automatically

• Device & usage data. IP address, browser type and version, device identifiers, operating system, pages viewed, referring URL, and timestamps.
• Cookies & similar technologies. Session cookies for authentication and abuse prevention, and a small number of first-party cookies for fraud and bot detection. We do not use third-party advertising cookies.

2. How We Use Your Information

We use information to:

• Operate, secure, and improve the Service;
• Verify identity and age, prevent fraud, prevent child-sexual-abuse material (CSAM), and enforce our Terms of Service;
• Process Token purchases, creator payouts, refunds, and chargeback disputes;
• Send transactional emails (account, billing, security) and, with your consent, marketing emails you can unsubscribe from at any time;
• Comply with legal obligations including 18 U.S.C. § 2257, tax reporting, sanctions screening, and lawful requests from authorities.

3. How We Share Information

We do not sell your personal information. We share it only as necessary to operate the Service:

• Identity verification. Yoti Limited (or a successor we disclose here).
• Payments and payouts. Ramp Network for fan token purchases (fiat → USDC on-ramp) and for creator payouts (USDC Send API to creator-designated wallets).
• Hosting & infrastructure. Hetzner Online GmbH (servers), Cloudflare, Inc. (network & storage), and other standard cloud subprocessors.
• Legal compliance. Government authorities, courts, or law-enforcement officers when we are legally required to do so, or when we believe in good faith that disclosure is necessary to protect the safety of our users or the public, including reports to NCMEC for suspected CSAM.
• Business transfers. In connection with a merger, acquisition, or sale of all or substantially all of our assets, subject to a confidentiality obligation and notice to you.

4. Data Retention

We keep account, content, and verification records as long as your account is active and for as long as required by law (including the seven-year minimum required by 18 U.S.C. § 2257 for performer records). We may keep limited transaction and abuse-prevention data after account deletion to defend against fraud and chargebacks and to meet tax recordkeeping requirements (typically up to seven years).

5. Your Rights

Depending on where you live, you may have the right to access, correct, delete, or port your personal information, to object to or restrict certain processing, and to lodge a complaint with a supervisory authority. Submit requests to privacy@fansxo.app. We will verify your identity before responding.

California residents (CCPA/CPRA): you have the right to know what we collect, the right to delete, the right to correct, and the right to opt out of the “sale” or “sharing” of your personal information. We do not sell or share your personal information for cross-context behavioral advertising.

EU/EEA & UK residents (GDPR/UK GDPR): our legal bases for processing are (a) performance of a contract, (b) our legitimate interests in operating and securing the Service, (c) your consent where required, and (d) compliance with legal obligations.

6. Security

We use industry-standard safeguards including TLS encryption in transit, encrypted database storage, hashed passwords, role-based access controls, and audit logging. No system is perfectly secure; please use a strong unique password and notify us immediately of any suspected compromise.

7. No Children

The Service is restricted to users 18 and older (or the age of majority in your jurisdiction, if higher). We do not knowingly collect, use, or sell personal information of anyone under 18. If we learn that an account belongs to a person under 18, we will terminate it immediately and delete the data.

8. International Transfers

FansXO is operated from the United States. If you access the Service from outside the United States, your information will be transferred to and processed in the United States, which may have data protection laws different from those in your country. Where required, we rely on Standard Contractual Clauses or other valid transfer mechanisms.

9. Changes

We may update this Privacy Policy from time to time. Material changes will be announced on the Service or by email at least seven (7) days before they take effect.

10. Contact