OnlyFaith Privacy Policy
Privacy Policy
BY USING ONLYFAITH, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THE INFORMATION IN THIS POLICY.
1. Introduction
1. OnlyFaith ("we", "us", "our") respects your privacy and we are committed to protecting the Personal Data we process about you. OnlyFaith is the owner and operator of www.onlyfaith.one ("OnlyFaith"), a religious, lifestyle, community features and content sharing platform which enables: (i) "Gurus" to share and monetise their own content (as well as subscribe to, and view, the content of other Gurus); and (ii) "Fans" to subscribe to, and view, the content of Gurus.
2. This privacy policy ("Policy") explains our practices with respect to the Personal Data processed about our Gurus and Fans. It also explains our practices with respect to the Personal Data processed about individuals that feature in content uploaded by a Guru ("Content Collaborators"), and where we process Personal Data in the context of our business relationships.
3. We process your Personal Data when you use OnlyFaith and for the provision of the services that we offer from time to time via OnlyFaith (the "Services"). 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.
4. 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.
2. What is Personal Data?
1. "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.
2. 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 anonymised information. This type of data is not Personal Data and our use of such data is not subject to this Policy.
3. Informing us of changes
1. 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 OnlyFaith.
4. Applicability of this Policy (18+)
1. This Policy is provided in addition to, but does not form part of, our Terms of Service that govern your use of the Services.
2. 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.
5. Third-party links
1. OnlyFaith 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.
2. 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.
6. If you do not wish to provide Personal Data
1. We need to collect certain Personal Data from you 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.
7. Updates to this Policy
1. We may update this Policy from time to time, and any updates will be effective upon our posting of the revised Policy on OnlyFaith. 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 an email.
8. Categories of Personal Data
1. We process, or our third-party providers process on our behalf, different kinds of Personal Data about Gurus, Content Collaborators and Fans, which we have grouped together as follows:
| Category of Personal Data | Description |
|---|---|
| User Data | Gurus
Fans
|
| Third-Party Onboarding Data | The following types of Personal Data are collected directly by our third-party providers during onboarding: Gurus
Fans
Please see Section 9 (our onboarding processes) for further information. Third-Party Onboarding Data and Technical Data does not include Face Recognition Data, as set out below. |
| Account Data | Gurus
Fans
|
| Financial Data | Gurus
Fans
Please note: Any payments made to view the content of Gurus 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 | Gurus
Fans
|
| Technical Data | Gurus and Fans Internet or other electronic network activity information, including:
|
| Usage Data | Gurus and Fans We use cookies where necessary to allow you to browse the Services and access certain pages of OnlyFaith. With your consent, we use non-essential cookies to enable us to recognise Referring Users, and Referred Creators, under the Referral Program in our Terms of Service. 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 behavioural advertising. |
| Face Recognition Data | Gurus and Fans where applicable
|
9. Onboarding processes
Gurus
1. We have processes in place that are intended to ensure that Gurus on OnlyFaith: (i) are at least 18 years of age; and (ii) verify their identity. Before you can start a Guru account, we will:
- - Ask you to provide Guru User Data, as set out at Section 8 (categories of Personal Data).
- - Check your country of residence. This check is intended to ensure lawful access to OnlyFaith and the Services.
- - Ask you to provide Financial Data, as set out at Section 8 (categories of Personal Data). This is necessary so that payments can be made to Gurus for content, and so that Gurus can access their earnings via OnlyFaith. 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, as described below.
- - Check that you have not previously been banned from using OnlyFaith and our Services (e.g. for violating our Terms of Service).
Fans
We have processes in place that are intended to ensure that: (i) all Fans on OnlyFaith are at least 18 years of age; and (ii) Fans in certain circumstances or locations verify their identity. Before you can start a Fan account, we will:
- - Ask you to provide Fan User Data, as set out at Section 8 (categories of Personal Data).
- - Check your country of residence. This check is intended to ensure lawful access to OnlyFaith and the Services.
- - Ask you to provide Financial Data, as set out at Section 8 (categories of Personal Data). This is necessary so that Fans can make payments to Gurus. Financial Data is also collected as a verification and anti-fraud measure.
- - Ask you to go through a third-party process to gain further assurances of your age. This may include a third-party age and identity verification process, or third-party age estimation process, as described below. The specific process will depend upon your location, or other circumstances (e.g. if we detect suspicious activity on your account).
Third-Party Age and Identity Verification
- - We use third-party providers to conduct age and identity verification.
- - 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 8 (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, as set out at Section 8 (categories of Personal Data), to maintain a record of the age and identity verification process.
More Information on Our Onboarding Processes
- 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 and preventing unlawful activity, and preventing fraudulent access to OnlyFaith.
- Periodic authentication of your age and 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.
10. How / why your Personal Data is used and lawful bases for processing
1. 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 Face Recognition Data by our third-party providers as part of the age and identity verification process for all Gurus (and for Fans in certain circumstances or locations). Please see Section 9 (our onboarding processes) 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 Fans and Gurus and process Guru 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 may include, for example, investigating and responding to a report made through our DMCA takedown procedure, to protect a Guru's intellectual property rights.
- - Compliance with legal obligations: We may process Personal Data to comply with applicable law, rules and regulations in the locations where we operate (e.g. complying with financial / tax reporting requirements).
- - 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 authorities and non-governmental organisations.
2. 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.
11. Obtaining your Personal Data
1. We collect your Personal Data from the following categories of sources:
- - Directly from you: When you provide it to us directly to open an account and use the Services, when you update your Personal Data in your account, or by corresponding with us (e.g. User Data, Account Data). We may also process your Personal Data when you interact with us through our social media pages on third-party websites.
- - Automatically or indirectly from you: For example, through and as a result of your use of the Services (e.g. Transaction Data, Technical Data, Usage Data), if you sign-in to OnlyFaith via third-party single sign-in, or if you connect a third-party account to your OnlyFaith account.
- - From our service providers: For example, where permitted by applicable law, we receive Third-Party Onboarding Data and certain Technical Data from our third-party age and identity verification providers.
12. Sharing your Personal Data
1. We share Personal Data with the following categories of third parties:
- - Our third-party service providers: Such as our IT, payment processing, customer support, content and text moderation, tax automation, and age and identity verification / age estimation service providers. The lawful basis we rely on for sharing Personal Data with these recipients is that it is necessary for our legitimate interests (namely the receipt of services to support business functionality).
- - Our professional advisers: Such as our legal advisors, bankers, auditors, accountants, consultants, and insurers. Our professional advisors will process Personal Data as necessary to provide their services to us. The lawful basis we rely on for sharing Personal Data with these recipients is that it is necessary for our legitimate interests (namely the receipt of professional services).
- - Corporate: Relevant third parties in the event of a possible sale, merger, acquisition, business reorganisation or group restructuring exercise. The lawful basis we rely on for sharing Personal Data with these recipients is that it is necessary for our and the relevant third parties' legitimate interests (namely assessing and putting into effect potential transactions).
- - Our group companies: For the centralised coordination and management of our business, in accordance with the purposes set out at Section 8 (categories of Personal Data). These recipients will process Personal Data in the same way as set out in this Policy. The lawful basis we rely on for sharing Personal Data with these recipients is that it is necessary for our legitimate interests (namely coordinating the global operations of our business).
- - Relevant authorities, regulators and organisations: Relevant governmental authorities (including law enforcement and tax authorities), regulators, and certain non-governmental organisations. These recipients will use your Personal Data in the performance of their regulatory, legal or otherwise charitable or not-for-profit role. Depending on the context, the lawful basis we rely on for sharing Personal Data with these recipients may vary. The processing may be necessary to comply with a legal obligation to which we are subject, necessary for our, or a third-party's, legitimate interests, or may be in the interest of the wider public to do so. This may include, for example, reporting illegal content to / assisting with requests from, authorities, regulators and organisations, to protect the safety of our users and third parties, and complying with our financial / tax reporting requirements.
13. Your rights regarding Personal Data
1. You have certain rights regarding the collection and processing of Personal Data. You may exercise these rights by contacting us using the contact details set out at Section 19 (assistance and contact information).
2. Under certain circumstances and subject to certain exemptions, you have the right to:
- - Withdraw your consent to the processing of your Personal Data: Please note that withdrawing your consent will not affect the lawfulness of any processing carried out before you withdraw your consent.
- - Request to know or access to your Personal Data: You may receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- - Request correction of the Personal Data that we hold about you: You may correct any incomplete or inaccurate Personal Data we hold about you.
- - Request deletion / erasure of your Personal Data: You may ask us to delete or remove Personal Data where there is no legitimate reason for us continuing to process it. You also may ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below). Please note that we may not always be able to comply with your request of deletion / erasure for specific legal reasons, for example if your account has been deactivated for violations of our Terms of Service. Please see Section 17 (retention of Personal Data) for further information.
- - Request the restriction of processing of your Personal Data: You may ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
3. You also have the right to object to processing of your Personal Data where we are relying on a legitimate interest for the processing and there is something about your particular situation which makes you want to object to processing on this ground.
14. Exercising your rights
1. If you would like to exercise your rights set out at Section 13 (your rights regarding Personal Data), you may do so by contacting us using the contact details set out at Section 19 (assistance and contact information).
2. If you submit the request yourself, please ensure that your request contains sufficient information to allow us to confirm your identity and properly understand, evaluate, and respond to it.
3. In order to verify your identity, we may at times need to request additional Personal Data from you, taking into consideration our relationship with you and the sensitivity of your request. In certain circumstances, we may decline a privacy rights request, particularly where we are unable to verify your identity.
4. If your request is made by a third-party authorised by you, we will also require proof that the third-party has permission to submit the request on your behalf (such as a signed document or a valid power of attorney evidencing that the third-party has authority to make the request).
15. Choices and control over your Personal Data
1. Modifying and deleting your Personal Data: If you have an account with us, you may update your account settings on OnlyFaith. Please note that changes to your settings may require some time to take effect.
2. Access to device information: You may control the Services' access to your Technical Data through your "Settings" app on your device. For instance, you can withdraw permission for the Services to access your network devices and geolocation.
3. Email notification opt-out: We currently do not send emails for direct marketing purposes. However, we do send email notifications which are related to your account (e.g. for Gurus, where you have a new subscriber, you have received a new tip, or somebody has renewed their subscription with you). You may opt-out of receiving certain types of email communications from us by changing your notification preferences on OnlyFaith. You may also email us using the contact details set out at Section 19 (assistance and contact information). Please include "E-mail notification opt-out" in the email's subject line and include your name and your account email address in the body of the email.
4. Please note that you cannot opt-out of certain automated email notifications that are necessary to provide the Services or are otherwise required in accordance with applicable law (e.g. account verification, transactional communications, changes / updates to features of the service, technical and security notices).
16. Retention of Personal Data
1. We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes for which it was collected, as set out in this Policy. The Personal Data that we retain and the length of time for which it is retained will be determined on a case-by-case basis, depending on the particular circumstances.
2. We determine the periods for which we normally retain Personal Data as follows:
- - Providing our Services: Where we need to use Personal Data to provide you with our Services, or specific parts of our Services, we will retain your Personal Data for the lifetime of your account or as long as necessary to provide you with the relevant feature or functionality of our Services.
- - Trust and safety: If you have (or we reasonably suspect that you have) violated our Terms of Service, or where we otherwise need to retain information to identify and report illegal activity or protect the safety of our users and third parties, we will retain certain Personal Data for as long as necessary to conduct our investigations, assist with any investigations by law enforcement or non-governmental authorities (e.g. NCMEC), and enforce any removal of offending users or content.
- - Compliance with applicable laws and regulatory obligations: For example: (i) identity record keeping / maintenance requirements in certain locations and financial / tax reporting requirements, which in some cases is up to 7 years; (ii) if we receive a valid legal request (such as a preservation order or search warrant, related to your account); (iii) complying with regulatory investigations or proceedings. We will delete your Personal Data sooner where a shorter retention period is required by applicable law.
- - Legal claims: Personal Data will be retained in accordance with applicable statutory limitation periods. In certain circumstances we may need to retain this longer, for example, to defend ourselves in litigation about a claim or complaint related to you.
17. Assistance and contact information
1. If you have questions about this Policy, or how we process your Personal Data, please email us at [email protected].