PRIVACY POLICY

  • Who we are
    Viisiion LLC and its subsidiaries ("Buhnanuh", "we", "us", "our") respect your privacy and we are committed to protecting the personal data we process about you. Buhnanuh is a social network which enables: (i) "Creators" to share and monetize their own content (as well as subscribe to, and view, the content of other Creators); and (ii) "Club Members" to subscribe to, and view, the content of Creators.

  • About this Policy
    This privacy policy ("Policy") explains our practices with respect to the personal data we process about our Creators and Club Members. Some parts of the Policy are specifically aimed at Creators, and some parts are specifically aimed at Club Members. It also applies to how we process the personal data of individuals that feature in content uploaded by a Creator ("Content Collaborators"), and where we process personal data about you in the context of our business relationships.

  • We process your personal data when you use our website located at www.Buhnanuh.com ("Website") and for the provision of the services that we offer from time to time via our 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 otherwise. We refer to these activities collectively as the "Services" in this Policy.

  • We are a "data controller" of the personal data that we process in connection with the Services. This means that we decide the reasons why we process personal data about you and how we do so.
    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 see Section 19 (assistance and contact information) for information about how to contact us.

  • What is personal data?
    "Personal data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household.
    In addition, we may collect data that is not capable of identifying you or is otherwise not associated or linked with you, such as deidentified, aggregated or anonymized information. This type of data is not personal data and our use of such data is not subject to this Policy.

  • Informing us of changes
    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes at any point during your relationship with us. Updates or corrections can be made through your “account settings” on our Website.

  • Applicability of this Policy (21+)
    This Policy is provided in addition to, but does not form part of, our Terms of Service (which includes our Acceptable Use Policy) that govern your use of our Website and the Services.
    Our Services are strictly intended for individuals 18 years of age or older. Anyone under 18 years of age is not permitted to use the Services. By using the Services, you represent that you are 18 years of age or older.

  • Third-party links
    Our Website may include 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, and this Policy does not apply to, the content, security or privacy practices of those other websites, plug-ins or applications. We encourage you to view the privacy and cookie policies / notices of those third parties to find out how your personal data may be used.

  • If you do not wish to provide personal data
    We need to collect certain personal data from you in order to provide you with access to the Services or specific features and functionalities of the Services in accordance with our contract with you (i.e. our Terms of Service). We are also required to process certain personal data in accordance with applicable laws. Please note that if you do not wish to provide personal data where requested, we may not be able to provide you with access to the Services or specific features and functionalities of the Services.

  • Updates to this Policy
    We may update this Policy from time to time, and any updates will be effective upon our posting of the revised Policy on our Website. We will use reasonable efforts to notify you in the event that material updates are made to this Policy, such as sending you a feed notification or a chat via your account on our Website.

  • Categories of personal data
    We process, or our third-party providers process on our behalf, different kinds of personal data about Creators and Club Members, which we have grouped together as follows:

 

Category of personal data

Description

User Data

Creators and Content Collaborators

full name*

alias, if applicable

residential address

country of residence*

email address

telephone number

a copy of the government identity document that you provide to us*

a "selfie" of you holding your government identity document*

third-party social media handle / personal website address (used to further verify your age and identity and to help us better understand the content which you are likely to share on our Website)

signature on release forms if you feature in another Creator's content*

Please note: Items marked with * will be required for Content Collaborators that are not existing Creators on the Website, via a release form.
Club Members

email address

telephone number

A selfie of you holding your government identity document*

                A copy of your government identity document that you provide  to us*

Payment method information such as a debit card or a credit  card* 

Birthday information such as Month, Day & Year for  verification.

Third-Party Onboarding Data

The following types of personal data are collected directly by our third-party providers during onboarding:


Creators

a copy of the government identity document that you provide to our third-party providers

a short .gif, taken from a “selfie” that you provide to our third-party providers

the results of the third-party age and identity verification process (pass / fail and reason for failing)

metadata associated with the third-party age and identity verification process (e.g. start and finish time)

 

Club Members

for locations where we conduct third-party age and identity verification of Club Members, a copy of the government identity document that you provide to our third-party providers

for locations where we carry out third-party age estimation, or third-party age and identity verification of Club Members, a short .gif, taken from a "selfie" that you provide to our third-party providers

the results of the third-party age estimation process or third-party age and identity verification process (pass / fail and reason for failing)

metadata associated with the third-party age estimation process or third-party age and identity verification process (e.g. user start and finish time)

Please see Section 10 (our onboarding processes), below, for further information. Third-Party Onboarding Data and Technical Data does not include Face Recognition Data, as set out below.

Account Data

Creators

profile name

password

avatars and headers of your Creator account

your subscriptions, subscribers and referrals

posts that you have made to your Creator account

comments on posts made from your Creator account

chat messages between you and other users

customer support queries that you submit to us

 

Club Members

profile name

password

avatars and headers of your Fan account

your subscriptions

comments on posts made from your Fan account

chat messages between you and other users

customer support queries that you submit to us

Financial Data

Creators

payment card details*

billing address

funds added to your wallet

bank account information

pay-out country

corporate or business entity if registered for tax purposes

social security number (for US Creators only) or other relevant tax information

W-9 form (for US Creators only)

1099-MISC form (for US Creators only)

1099-NEC form (for US Creators only)

Club Members

payment card details*

billing address

funds added to your wallet

* Please note: Any payments made to view the content of Creators are processed by our third-party payment providers. We do not receive your full payment card number, payment card expiration date, or the security code. Instead, the payment provider provides us with a "token" that represents your account, your payment card's expiration date, payment card type and the first six and last four digits of your payment card number.

Transaction Data

Creators

Earnings

Pay-out requests

Payments made to your Creator account

Payments made from your Creator account to other Creators

Any failed payments

Club Members

Payments made from your Member account to Creators

Any failed payments

Technical Data

Creators and Club Members
Internet or other electronic network activity information, including:

internet protocol (IP) address (and associated location data)

Internet Service Provider (ISP)

device and type

name and version of browser

Usage Data

Creators and Club Members
We use cookies where necessary (to allow you to browse the Services and access certain pages of the Website) and, with your consent we will use cookies:

for performance on the Website (e.g. to analyze how users interact with the Website to improve the Services and, where you are a Creator, so that we can recognize that you have referred another Creator through your unique referral code)

for Website functionality (e.g. saving your logged-in status)

More information on our use of cookies, including how to delete or block cookies, can be found in our Cookie Notice. In some cases, data collected from cookies will be in a deidentified, aggregated or anonymized format.
We currently do not use any cross-site tracking technologies and we do not sell personal data collected about you, or share personal data collected about you for cross-context behavioral advertising.

Face Recognition Data

Creators (and Club Members in certain locations)

As described in more detail below in Section 10 (our onboarding processes), during onboarding, our third-party providers may use face recognition technology, so they can digitally verify you.

The Face Recognition Data remains with our third-party provider and we do not ourselves collect, receive, possess, or have access to Face Recognition Data at any time.

 


  • Our onboarding processes
    CREATORS
    We have processes in place that are intended to ensure that all Creators on the Website: (i) are at least 18 years of age; and (ii) verify their identity. Before you can start a Creator account, we will:
    • Ask you to provide Creator User Data, as set out at Section 9 (categories of personal data).
    • Check your country of residence. This check is intended to ensure lawful access to the Website and the Services.
    • Ask you to provide Financial Data, as set out at Section 9 (categories of personal data). This is necessary so that payments can be made to Creators for content, and so that Creators can access their earnings via the Website. Financial Data is also collected as a verification and anti-fraud measure.
    • Ask you to go through a third-party age and identity verification process:
      • This process involves our third-party provider collecting a short .gif, taken from a "selfie" and photo from a government identity document (in both cases, that you provide to the third-party provider). The third-party provider then uses Face Recognition Data to match the two images so they can digitally verify your age and identity.
      • As described at Section 9 (categories of personal data), we do not collect, receive, possess, or have access to any Face Recognition Data collected or processed by our third-party providers through this process.
      • Where permitted by applicable law, we receive from our third-party providers Third-Party Onboarding Data, and certain Technical Data, as set out at Section 9 (categories of personal data), to maintain a record of the age and identity verification process.
    • Check that you have not previously been banned from using the Website and our Services (e.g. as a result of violating our Terms of Service).
  • Club Members
    We have processes in place that are intended to ensure that: (i) all Club Members on the Website are at least 18 years of age; and (ii) Club Members in certain locations verify their identity. Before you can start a Fan account, we will:
    • Ask you to provide Club Member User Data, as set out at Section 9 (categories of personal data).
    • Check your country of residence. This check is intended to ensure lawful access to the Website and the Services.
    • Ask you to provide Financial Data, as set out at Section 9 (categories of personal data). This is necessary so that Club Members can make payments to Creators. Financial Data is also collected as a verification and anti-fraud measure.
    • Ask you to go through a third-party process to gain assurances of your age. The specific process will depend upon your location and the third-party provider. This may include:
      • Third-party age and identity verification
        • For certain locations, we are required to verify the age and identity of our Club Members, so we need to take additional steps. This process involves our third-party provider collecting a short .gif, taken from a "selfie" and photo from a government identity document (in both cases, that you provide to the third-party provider). The third-party provider then uses Face Recognition Data to match the two images so they can digitally verify your age and identity.
        • As set out at Section 9 (categories of personal data), we do not ourselves collect, receive, possess, or have access to this data.
        • Where permitted by applicable law, we may receive from our third-party providers Third-Party Onboarding Data, and certain Technical Data, as set out at Section 9 (categories of personal data), to maintain a record of the age and identity verification process.
      • Third-party age estimation
        • For certain locations, we use third-party providers to conduct age estimation. This process involves our third-party provider collecting a short .gif "selfie" (that you provide to the third-party provider) and using digital technology to estimate your age, which may involve the use of Face Recognition Data.
        • If you go through the third-party age estimation process, we will only receive the results of the process (pass / fail and reason for failing), to maintain a record of the age estimation process.
        • If you fail the third-party age estimation process (e.g. if you are over 18 years of age, but their technology has predicted that you look under 18 years of age), you may have the option to go through the third-party age and identity verification process set out above.
  • MORE INFORMATION ON OUR ONBOARDING PROCESSES
    • Why does Buhnanuh use third-party face recognition technology?
      • The use of face recognition technology by our third-party providers is an important technological measure used in our wider onboarding processes for Creators and Club Members. It is intended to ensure safety on the Website and our compliance with applicable laws.
      • We use third-party service providers to carry out age and identity verification, who carry out these services on our behalf, as data processors.
    • How does Face Recognition Data help to prevent fraud?
      • Face recognition technology reduces the possibility of fraudulent face image spoofing and the uploading of fraudulent government identity documents when individuals go through the onboarding process.
      • Where our third-party providers have identified possible fraud attempts (such as the use of fake or otherwise manipulated documents) our third-party providers may maintain a record of such attempts, including Face Recognition Data, for the purposes of detecting unlawful activity and preventing access to the Website.
    • Periodic authentication of your identity
      • During the time that you hold an account with us, we may require you to periodically authenticate your identity. If you have gone through the third-party age identity verification process, where permitted by applicable law our third-party providers may retain Face Recognition Data to enable you to authenticate your identity. Where this is retained, you do not need to provide the third-party provider with your government identity document again when authenticating your identity.
      • Withdrawing your consent: You may withdraw your consent to the retention of your Face Recognition Data for the purposes of subsequent authentication (and delete this) by contacting support@buhnanuh.com While withdrawing your consent to the retention of your Face Recognition Data will not affect your ability to complete a subsequent authentication process, it may require you to provide the third-party provider with your government identity document again during the authentication process.
  •  

  • How / why your personal data is used and lawful bases for processing
    We process personal data for, or based on, one or more of the following legal bases:
    • Consent: Your consent is requested only in specific circumstances which includes, for example, the processing of: (i) Face Recognition Data by our third-party providers as part of the age and identity verification process for all Creators (and for Club Members in certain locations); and (ii) age estimation captures (which may involve the use of Face Recognition Data) by our third-party providers for Club Members in certain locations. Please see Section 10 (our onboarding processes), above, for further information.
    • Performance of a contract: By using the Services, you have contracted with us through our  Terms of Service, and we will process personal data to perform that contract (e.g. to fulfil transactions between Club Members and Creators and process Creator earnings) and to enforce the terms of that contract.
    • Legitimate interests: We may process personal data if it is in our, or a third-party's, legitimate interests (as detailed in the table below). This includes, for example, investigating and responding to a report made through our DMCA Takedown Procedure to protect a Creator's intellectual property rights.
    • Compliance with legal obligations: As a global business, we may process personal data to comply with applicable law, rules and regulations in the locations where we operate.
    • Task carried out in the public interest: We may process personal data as necessary for a task carried out in the public interest. This may include, for example, reporting illegal activity to relevant law enforcement authorities, other governmental agencies and non-governmental organizations.
  • 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 indicates the purposes for which your personal data is processed and the legal justification for the processing. Some of the above grounds for processing will overlap and there may be several grounds which justify the processing: