creoviva Privacy Policy
This Privacy Policy explains how Ember Eagle Ltd processes personal data in connection with creoviva, the platform that hosts each creator's own public page, sessions and videos.
1. Controller
Ember Eagle Ltd, 71-75 Shelton Street, WC2H 9JQ London, United Kingdom, company number TBD, is the data controller for the processing described in this Policy, except where a different role is stated. Privacy contact: TBD.
2. Data we collect
- Account data: name, display name, email, credentials and account status.
- Creator data: profile, biography, image, preferences, payment details and verification information.
- Identity and age verification information where required.
- Customer data: account information, messages, session requests and support correspondence.
- Content: videos, images, profile information, messages and related metadata.
- Technical data: IP address, device/browser data, operating system, logs, timestamps and security events.
- Billing and credit data: credit purchases, platform charges, invoices, transaction IDs and payment status.
- Safety data: reports, moderation records, fraud indicators, restrictions and related correspondence.
3. Purposes and legal bases
- Providing accounts and Platform services (legal basis: contract).
- Creator onboarding and age/identity checks (legal basis: contract and/or legal obligation, as applicable).
- Credits, subscriptions, invoices and accounting (legal basis: contract and legal obligation).
- Security, moderation and fraud prevention (legal basis: legitimate interests and/or legal obligation).
- Preventing and responding to illegal content (legal basis: legal obligation and/or legitimate interests).
- Customer support (legal basis: contract and/or legitimate interests).
- Marketing (legal basis: consent or legitimate interests where legally permitted).
The exact legal basis for each processing activity will be documented in creoviva's internal processing register.
4. User content and illegal-content processing
Because creoviva supports user-generated content and live interactions made available by creators through their own creator pages, we process content and associated metadata for delivery, security, moderation, legal compliance and user protection.
If suspected illegal content or criminal conduct is identified, we may preserve relevant information and disclose it to law enforcement or another competent authority where required or permitted by law. This may justify retention after an account is closed.
5. Sensitive information
Users should not submit health, biometric, criminal-history or other special-category information through ordinary profile fields unless specifically requested for a lawful purpose. Specialist verification providers may process identity or age information under appropriate safeguards.
6. Cookies
We may use necessary cookies for authentication, security and Platform functionality, including a cookie that records whether a visitor has clicked through a creator page's 18+ age gate. Optional analytics or marketing technologies will be used only where applicable consent or another lawful basis exists. A separate Cookie Policy/consent interface may apply.
7. Providers and disclosures
We may use hosting, cloud, content delivery, email, authentication, identity/age verification, security, analytics, support, payment and compliance providers. We may also disclose data to advisers, auditors, regulators, courts and law enforcement where appropriate.
The final published version should include the actual subprocessor/provider list and links.
8. International transfers
Where personal data is transferred outside the UK or EEA, creoviva will use an applicable lawful transfer mechanism and appropriate safeguards, such as adequacy decisions, EU Standard Contractual Clauses, the UK International Data Transfer Agreement/Addendum or another lawful mechanism.
9. Retention
- Financial records: for the period required by applicable tax/accounting law.
- Safety and moderation records: as long as reasonably necessary for enforcement, appeals, legal claims and regulatory obligations.
- Law-enforcement preservation: longer retention may apply where legally required or reasonably necessary to preserve evidence.
10. Your rights
- Access, correction and deletion where applicable.
- Restriction or objection to certain processing.
- Withdrawal of consent where consent is the legal basis.
- Data portability where applicable.
- Right to complain to the relevant data protection supervisory authority.
Requests: TBD. We may verify identity before responding.
11. Children
creoviva is an 18+ service for age-restricted functionality. We do not knowingly permit children to create creator accounts, purchase age-restricted content or participate in age-restricted sessions. If we identify an underage account, we may restrict or remove it and take appropriate safety and data-protection steps.
12. Automated systems
Automated systems may be used for security, fraud prevention, spam detection and content triage. Where applicable law provides rights concerning solely automated decisions with legal or similarly significant effects, creoviva will provide the required safeguards.
13. Security
We use appropriate technical and organisational measures to protect personal data. No online service can guarantee absolute security.
14. Changes
We may update this Policy and will publish the latest version with its effective date.
15. Contact
Privacy: TBD
Safety / illegal content: TBD
Registered office: 71-75 Shelton Street, WC2H 9JQ London, United Kingdom
Company number: TBD