Privacy Policy – Fan-Verse

Effective Date: [●] | Last Updated: [●]

Your privacy matters. This Privacy Policy explains what data Fan-Verse.ai collects, how we use it — including for AI model training — how we share it, and your rights. California residents have additional rights under CCPA/CPRA including the right to opt out of the sharing of personal information for cross-context behavioral advertising. See Section 10 for California-specific rights. Do Not Sell or Share My Personal Information: fan-verse.ai/legal/privacy#do-not-sell

1. Who We Are
Fan-Verse.ai is operated by Clocr, Inc., a Delaware corporation doing business as FANVERSEAI, operating as Fan-Verse.ai (“Fan-Verse.ai,” “we,” “us,” or “our”). We are an AI-powered digital engagement platform. Our registered address is on file with the State of Delaware; contact us at privacy@fan-verse.ai for privacy inquiries.

This Privacy Policy applies to all users of fan-verse.ai and our mobile applications, including users who access our platform through a co-branded partner interface. If you access Fan-Verse.ai through a co-branded partner’s platform, Fan-Verse.ai — not the partner — is the entity responsible for this Privacy Policy.

2. Information We Collect
2.1 Information You Provide Directly

Category What We Collect
Account data Name, email address, date of birth (for age verification), username, and password when you register
Profile data Profile photo, bio, social media handles, and other information you add to your profile
Content you submit Text, images, audio recordings, video recordings, scripts, and other content you submit to the platform — including voice samples and likeness captures if you are a creator participant
Payment data Payment method information when you make purchases — processed by our payment processor (Stripe); we do not store full card details
Communications Messages you send to Fan-Verse.ai support or through platform messaging features
Consent records Records of consents you provide, including AI cloning consent, Creator Supplemental Terms acceptance, and — for creator participants who submit voice recordings or likeness captures — the separately executed Biometric Data Handling Notice required by applicable biometric privacy laws (BIPA, CUBI, and equivalent state statutes)

2.2 Information We Collect Automatically

Category What We Collect
Usage data Pages viewed, features used, content accessed, digital twins interacted with, session duration, and interaction patterns
Engagement data How you engage with digital twin content — messages sent, reactions, time spent, content preferences
Device & technical data IP address, browser type, operating system, device identifiers, and referring URL
Location data Approximate location derived from IP address (city/state level). We do not collect precise GPS location unless you explicitly grant permission
Cookies & tracking Cookies, pixel tags, and similar tracking technologies — see Section 12 for details
Log data Server logs including access times, error logs, and diagnostic information

2.3 Information from Partners & Third Parties

Category What We Collect
Co-branded partner data If you access Fan-Verse.ai through a co-branded partner’s platform, the partner may share your account or authentication information with us to facilitate your account creation
Social media If you connect a social media account to Fan-Verse.ai, we receive basic profile information from that platform per their permissions
Analytics providers Aggregated analytics data from third-party analytics services we use to understand platform usage

3. How We Use Your Information
3.1 To Operate the Platform
Create and manage your account; verify your identity and age; deliver platform features; process payments; send transactional communications (receipts, security alerts, account notifications); provide customer support; and display your content via your digital twin if you are a creator.

3.2 AI Model Training — Special Disclosure
AI Training Disclosure. Fan-Verse.ai uses content you submit — including voice recordings, video, images, and text — to train, improve, and maintain AI voice cloning, likeness synthesis, and persona modeling systems used to operate the platform. This is a core part of how our technology works. Under California AB 2602 and applicable federal law, we are required to disclose this use explicitly. California residents may have rights regarding this use — see Section 10. We use only content you have submitted and authorized for this purpose. We do not use your data to train general-purpose AI models sold or licensed to third parties.

3.3 Platform Improvement & Analytics
Understand how the platform is used; improve features and performance; develop new products; conduct research on engagement patterns; and produce aggregated analytics. This processing uses de-identified or anonymized data wherever possible.

3.4 Safety, Security & Compliance
Detect and prevent fraud, abuse, prohibited content, and security incidents; enforce our Terms of Service; respond to legal requests; protect the rights, property, and safety of Fan-Verse.ai, our users, and the public; and comply with applicable laws.

3.5 Marketing & Communications
Send promotional emails, newsletters, and platform updates. You may opt out of marketing communications at any time by clicking “unsubscribe” in any email or updating your notification preferences in account settings. Opting out of marketing does not affect transactional communications.

3.6 Co-Branded Partner Analytics
Provide co-branded partners with aggregate, de-identified analytics about how their audience engages with their content on the platform. We do not share your individual personal information with co-branded partners — only aggregated performance data.

4. How We Share Your Information
4.1 Service Providers & Subprocessors
We share information with third-party service providers who help us operate the platform, including: cloud hosting (AWS/Google Cloud); payment processing (Stripe); email delivery; analytics; customer support tools; AI infrastructure providers; and content delivery networks. All service providers are bound by confidentiality and data processing agreements that restrict their use of your data to providing services to us.

4.2 Co-Branded Partners — Limited
Co-branded partners receive only aggregate, de-identified analytics about their audience’s engagement with their content. We do not share your name, email, account data, or any personally identifiable information with co-branded partners without your explicit consent.

4.3 Creator Relationships
If you interact with a creator’s digital twin, the creator may have access to aggregate analytics about how their audience engages with their content. Creators do not receive your personal contact information. If you send messages to a creator’s digital twin, those messages may be reviewed by the creator to improve their content.

4.4 Business Transfers
If Fan-Verse.ai is involved in a merger, acquisition, financing, or sale of all or substantially all of our assets, your information may be transferred as part of that transaction. We will notify you via email or prominent in-platform notice at or around the time your data is transferred, and before it becomes subject to a materially different privacy policy, to the extent practicable given the circumstances of the transaction.

4.5 Legal Requirements
We may disclose your information if required by law, court order, or governmental authority, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Fan-Verse.ai, our users, or the public.

4.6 What We Do Not Do
Fan-Verse.ai does not sell your personal information to third parties for their independent marketing purposes. Fan-Verse.ai does not share your personal information with advertisers for targeted advertising. We do not display advertisements on the platform. Our service does not support ad-targeting profiles built on your personal data.

5. AI Training — Your Data & Your Rights
Fan-Verse.ai’s platform is powered by AI systems including voice cloning, likeness synthesis, and interaction modeling. Here is exactly what we use, what we don’t use, and what rights you have:

5.1 What We Use for AI Training
• Voice recordings and audio samples you submit as a creator
• Video and image content you submit as a creator
• Scripts, dialogue, and written content you submit for your digital twin
• Anonymized interaction patterns and engagement signals (how users engage with the platform generally)

5.2 What We Do Not Use
• We do not use your personal messages to third parties or private communications for AI training
• We do not use your payment data for AI training
• We do not sell training data to third parties
• We do not use your data to train general-purpose AI models that are independently licensed or sold

5.3 AI Model Persistence
AI models trained on your voice and likeness during your time on the platform incorporate statistical representations that cannot be reverse-engineered to reproduce your identity independently. When your account is closed or your digital twin is deactivated, we cease active use of your likeness in new content generation. However, trained AI models incorporate your voice and likeness as statistical representations and persist as internal systems. The license you granted to Fan-Verse.ai for Captured NIL/Identity under your Creator Supplemental Terms or Independent Talent & Equity Incentive Agreement (ICA) is perpetual and irrevocable as a technical necessity of AI model training — AI systems cannot be un-trained. We will not use your voice or likeness to generate new content attributed to you after your twin is deactivated. California residents have specific rights regarding this; see Section 10.

6. Data Retention
We retain your personal data for as long as your account is active and as necessary to provide the platform services. Specific retention periods:

Category Retention Period
Account data Retained while your account is active, plus 90 days after deletion to allow for account recovery, then deleted
Content & creator submissions Retained while your digital twin is active. On deactivation, raw content files are deleted within 90 days after the applicable wind-down period ends (90 days for university program participants; 180 days for direct creator participants). If no wind-down period applies, deletion occurs within 90 days of deactivation. AI model representations persist as described in Section 5.3
Payment records Retained for 7 years for tax and accounting compliance
Usage & engagement data Retained for 24 months, then aggregated or deleted
Security & fraud logs Retained for 12 months
Legal hold data Retained as required by applicable legal obligations

You may request deletion of your account and personal data as described in Section 9. We will comply within 45 days except where retention is required by law or necessary to resolve disputes, enforce agreements, or maintain security.

7. Security
We maintain reasonable administrative, technical, and physical safeguards designed to protect your personal data against unauthorized access, disclosure, alteration, and destruction, consistent with industry standards for platforms handling similar data and AI systems. These include encryption in transit (TLS) and at rest, access controls, monitoring, and regular security assessments.

No security system is impenetrable. In the event of a data breach involving your personal information, we will notify you in accordance with applicable law — within 72 hours of confirmation where required by GDPR, and within applicable state law timelines for US states with breach notification requirements. Contact security@fan-verse.ai to report security concerns.

8. Children — Minimum Age 18
Fan-Verse.ai is not directed at and does not knowingly collect personal data from anyone under 18 years old. Our Terms of Service require users to be at least 18. If we become aware that we have collected personal data from a person under 18, we will delete that data and terminate the account promptly. If you believe we have inadvertently collected data from someone under 18, contact us at privacy@fan-verse.ai.

9. Your Privacy Rights — All Users
Regardless of your location, you have the following rights with respect to your personal data:

Access
Request a copy of the personal data we hold about you. We will provide this within 45 days of a verified request.
Correction
Request correction of inaccurate or incomplete personal data. You can update most account information directly in your account settings.
Deletion
Request deletion of your personal data, subject to retention obligations described in Section 6. Submit deletion requests through account settings or at privacy@fan-verse.ai.
Data Portability
Request your account data in a machine-readable format. We will provide this within 45 days.
Opt Out of Marketing
Opt out of marketing communications at any time via the unsubscribe link in any email or in account notification settings.

To exercise any of these rights, contact us at privacy@fan-verse.ai or visit fan-verse.ai/legal/privacy-request. We will verify your identity before processing requests. We will not discriminate against you for exercising your privacy rights.

10. California Residents — CCPA / CPRA Rights
California Residents. If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). This section describes those rights and how to exercise them.

10.1 Categories of Personal Information We Collect (CCPA)
In the past 12 months, we have collected the following categories of personal information as defined by CCPA:

Category What We Collect
Identifiers Name, email address, IP address, device identifiers, account username
Personal records Date of birth (age verification), payment information (processed by Stripe)
Protected class info Age (collected only for 18+ verification — not used for discrimination)
Commercial data Purchase history, subscription status
Biometric identifiers Voice recordings and likeness captures submitted by creator participants (with explicit consent)
Internet/network activity Browsing history on our platform, interaction data, content viewed
Inferences Engagement preferences and content affinity inferred from platform usage
Audio/visual Voice recordings and video submitted by creator participants

10.2 Your CCPA / CPRA Rights
• Right to Know — what personal information we collect, use, share, and sell
• Right to Delete — request deletion of your personal information, subject to exceptions
• Right to Correct — request correction of inaccurate personal information
• Right to Opt Out — opt out of the sale or sharing of your personal information
• Right to Limit — limit use of sensitive personal information
• Right to Non-Discrimination — we will not discriminate for exercising CCPA rights
• Right to Data Portability — receive your data in a usable format

10.3 Do Not Sell or Share My Personal Information
Fan-Verse.ai does not sell your personal information for monetary consideration. However, under CCPA/CPRA, sharing personal information for cross-context behavioral advertising may constitute “sharing.” Fan-Verse.ai does not engage in cross-context behavioral advertising. To submit a “Do Not Sell or Share” request: visit fan-verse.ai/legal/privacy#do-not-sell, email privacy@fan-verse.ai with subject “Do Not Sell,” or use the link in our platform footer. We will honor your request within 15 business days.

10.4 AI Training — California Opt-Out Right
Under California law, you may request that Fan-Verse.ai limit the use of your voice recordings and likeness captures for AI model training purposes beyond operating your own digital twin. This right applies to creator participants. Submit requests to privacy@fan-verse.ai with subject “AI Training Opt-Out.” Note: opting out may affect the quality and functionality of your digital twin, as AI training is required to create and maintain voice and likeness clones.

10.5 Authorized Agents
California residents may designate an authorized agent to make CCPA requests on their behalf. We will verify the agent’s authorization before processing. Contact privacy@fan-verse.ai for instructions.

10.6 How to Submit California Privacy Requests
Email: privacy@fan-verse.ai | Subject line: “California Privacy Request” | Include: your full name, account email, and the specific right you are exercising. We will acknowledge within 10 business days and fulfill within 45 days (extendable by 45 days with notice). For users whose requests are governed by GDPR, we fulfill within 30 days (extendable to 90 days with notice for complex requests).

10.7 Shine the Light
California Civil Code §1798.83 permits California residents to request information about personal information disclosed to third parties for direct marketing purposes in the prior calendar year. Fan-Verse.ai does not disclose personal information to third parties for their direct marketing purposes.

11. EU / UK Residents — GDPR Rights
Note on EU/UK operations. Fan-Verse.ai currently operates in the United States. This section establishes your GDPR and UK GDPR rights. Fan-Verse.ai will implement full EU/UK operational infrastructure — including a designated EU representative and data transfer mechanisms — prior to actively marketing to EU or UK users. Your rights under this section are enforceable now to the extent GDPR applies to your use of our platform.

11.1 Lawful Basis for Processing

Category Lawful Basis
Account operations Contract performance — processing is necessary to provide the services you signed up for
AI model training (creators) Consent — we obtain explicit consent for voice and likeness capture and AI training through Creator Supplemental Terms acceptance
Analytics & platform improvement Legitimate interests — improving our platform, provided this does not override your fundamental rights
Marketing Consent — you can withdraw at any time
Safety & legal compliance Legal obligation and legitimate interests

11.2 Your GDPR Rights
• Access (Article 15) — obtain a copy of your personal data
• Rectification (Article 16) — correct inaccurate personal data
• Erasure (Article 17) — request deletion (“right to be forgotten”), subject to legal retention obligations
• Restriction (Article 18) — restrict processing in certain circumstances
• Portability (Article 20) — receive your data in a structured, machine-readable format
• Objection (Article 21) — object to processing based on legitimate interests
• Withdraw Consent (Article 7) — withdraw consent for consent-based processing at any time without affecting prior processing

11.3 International Data Transfers
Fan-Verse.ai is based in the United States. If you are located in the EU or UK, your personal data is transferred to and processed in the US. We rely on Standard Contractual Clauses (SCCs) approved by the European Commission for such transfers where required. Prior to active EU marketing, we will finalize all applicable transfer mechanisms.

11.4 Right to Lodge a Complaint
You have the right to lodge a complaint with your local data protection authority if you believe we have processed your personal data in violation of GDPR. For EU users, the lead supervisory authority contact is available at edpb.europa.eu. For UK users, contact the Information Commissioner’s Office at ico.org.uk.

12. Cookies & Tracking Technologies
We use cookies and similar technologies to operate the platform, remember your preferences, analyze usage, and maintain security. Types of cookies we use:

Category What We Collect
Strictly necessary Required for the platform to function — authentication, security, session management. Cannot be disabled.
Functional Remember your preferences and settings. Can be disabled but may affect platform functionality.
Analytics Help us understand how the platform is used — pages viewed, features used, session duration. Anonymized where possible.
No advertising cookies Fan-Verse.ai does not use advertising or targeting cookies. We do not participate in cross-site advertising networks.

You can manage cookie preferences through your browser settings. For EU/UK users, we will present a consent banner for non-essential cookies prior to EU launch. Blocking strictly necessary cookies will prevent the platform from functioning.

13. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in our data practices, legal requirements, or platform features. We will notify you of material changes by email to your registered address and by prominent in-platform notice at least thirty (30) days before the change takes effect. For changes that require your consent (such as new uses of biometric data), we will seek your affirmative consent before the change applies to your data. We encourage you to review this policy periodically. The “Last Updated” date at the top indicates when the most recent changes were made.

14. Contact Us — Privacy Inquiries
For privacy questions, requests, or concerns:

Privacy Officer: privacy@fan-verse.ai
Legal inquiries: legal@fan-verse.ai
Security issues: security@fan-verse.ai
Mail: Clocr, Inc. d/b/a FANVERSEAI, Attn: Privacy, [Address]
Privacy request portal: fan-verse.ai/legal/privacy-request

We will acknowledge privacy requests within 10 business days and respond fully within 45 days. For urgent security incidents, contact security@fan-verse.ai with “URGENT” in the subject line.