Privacy Policy

Last updated 2026-08-24

1. General Information

1.1 Definitions

Personal data is information that discloses or may disclose the identity of the user. We adhere to the principle of data avoidance. The collection of personal data is avoided as far as possible.

Fangate is an app that enables users (referred to as "Uploaders") to upload content to Fangate's server, making it accessible to third parties ("Downloaders") via a URL hyperlink in exchange for a payment.

Other applications may have their own Privacy Policies, as available through their respective hyperlinks and/or sites.

  • Account: An online account on the Fangate application assigned to the Uploader, accessible through the application using the Uploader's Credentials.
  • Application or app: The application through which the Services are available to the Uploader.
  • Credentials: The dedicated email address and password for an Account, necessary for the Uploader to access their account. These are personal and private to each Uploader.
  • Data Protection Laws: Refers to (i) Regulation (EU) 2016/679 (GDPR) and (ii) where applicable, regulations adopted within the European Union and local laws elsewhere that may apply to personal data processed under the scope of the Uploader Terms of Use.
  • Downloader: Any natural person who navigates to a Download Page and uses it to download a File in exchange for payment.
  • Download Page: A webpage published by Fangate and accessible via a dedicated URL, where the Downloader can access and download a File.
  • File: A digital file uploaded by an Uploader using the Service, made available for access and download in exchange for payment.
  • Stripe: Stripe, Inc. (US), Stripe Payments Europe, Ltd (EU), or Stripe Payments UK, Ltd (UK), depending on Uploader location. More information at stripe.com/legal.
  • Uploader: Any natural person who uses the Services to make Files available on the Application.

1.2 Handling of Personal Data

Personal data is utilized solely for forming a contract, determining its content, executing, or managing the contractual relationship, as per Article 6(1)(b) of the GDPR. Personal data is processed within the EU and in countries deemed secure or appropriate by the EU. If personal data is processed in the USA, we strive to use services certified under the "Data Privacy Framework".

1.3 Duration of Storage

We only store your personal data after the end of the purpose for which the data was collected for as long as this is required by law (in particular tax law).

1.4 Usage Data

General technical information is collected when you visit the website and the application. This includes the IP address used, time, device type, duration of the visit, browser type and, if applicable, the originating page. This usage data is not linked to your other personal data.

1.5 Registration/Login Data

Registration or login is necessary to fully access the features of our website or service. The data required for registration or login is gathered through your inputs and is used solely for the purposes explicitly stated, with your consent, in accordance with Article 6(1)(a) of the GDPR.

1.6 Personal Data Categories

Upon using our services, access to the following types of data is given:

  • Type of end device and use of the application
  • E-mail address and credentials
  • Time zone and country of origin
  • Photos/media/data
  • Banking and transaction information (payment amount, account numbers, date)

2. Data Safety

2.1 General

All data on our website and in our services is protected by technical and organizational measures against loss, destruction, access, modification and dissemination.

2.2 Sessions and Cookies

We use cookies or server-side sessions in which data can be stored to operate the website. We ensure that no personal data is transferred from sessions or through cookies without your express consent and that cookies are only used if this is technically necessary for the website. We use cookies after your express consent to personalize content and advertisements, to be able to offer functions for social media and to analyze access to our website.

3. Your Rights

3.1 Information

You can request information from us as to whether we process your personal data and, if this is the case, you have a right to information about this personal data and to the further information specified in Art. 15 GDPR.

3.2 Right to Rectification

You have the right to rectification of inaccurate personal data concerning you and may request the completion of incomplete personal data in accordance with Art. 16 GDPR.

3.3 Right to Erasure

You have the right to demand that we erase personal data concerning you without undue delay, in particular if: your data is no longer necessary for the purposes it was collected, you withdraw your consent, or your data has been processed unlawfully. The right to erasure does not exist if your personal data is required for the assertion, exercise or defence of our legal claims.

3.4 Right to Restriction of Processing

You have the right to demand that we restrict the processing of your personal data in certain circumstances, including if you dispute the accuracy of the data, you have objected to the processing, the processing is unlawful, or we no longer need the data but you need it for legal claims.

3.5 Right to Data Portability

You have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format and to transmit that data to another controller.

3.6 Right of Cancellation

If the processing of your personal data is based on consent, you have the right to withdraw this consent at any time.

3.7 Right to Lodge a Complaint

The exercise of your above rights is generally free of charge for you. In the event of complaints, you have the right to contact the supervisory authority responsible for us, the state data protection officer.

4. Third-Party Services

4.1 Google Analytics

This website employs Google Analytics, a web analytics service provided by Google Ireland Limited, located at Gordon House, Barrow Street, Dublin 4, Ireland. It uses "cookies" to analyze how you use the website. Google Analytics is utilized only with your consent, in accordance with Article 6(1)(a) of the GDPR. You can view Google's privacy policy at google.com/policies/privacy.

4.2 Google Web Fonts

We use web fonts from Google Ireland Limited to display a standardised font on our website. These are automatically stored in your browser cache when you access one of our pages.

4.3 Social Media Login

You may log in via your existing Google, Facebook, or Apple social media account. The data protection provisions and terms of use of the respective provider apply.

4.4 Google Firebase and Firebase Cloud Messaging

Our website and/or services may use Google Firebase (operated by Google Ireland Limited). This service processes personal data including "instance IDs" provided with timestamps. Firebase Cloud Messaging is used to send push messages. You can view the privacy policy at firebase.google.com/support/privacy.

4.5 Cloud Import (Dropbox, Google Drive, Microsoft OneDrive)

Creators can choose to import files they own from their personal cloud storage accounts. When a creator actively connects such an account, the selected files are retrieved directly by our servers on the creator's instruction, based on a short-lived access authorization (OAuth) granted through the respective provider. We do not store the account credentials; access tokens are used only for the duration of the import session. Transferred files transit through our upload infrastructure hosted on Amazon Web Services (USA) and are then subject to the same review, moderation and retention rules as direct uploads. Each import requires the creator's explicit confirmation that they hold the necessary rights and consents for the imported material. The providers act as independent data controllers for the creator's own cloud account; their respective privacy policies apply.

4.6 Age Verification (Yoti)

Where age verification is required for a purchase, it is performed by Yoti (Yoti Ltd, London, UK) using facial age estimation. The camera image is processed by Yoti to estimate age and is not transmitted to or stored by Fangate; Fangate only receives and stores the result (passed / not passed) linked to the purchase. The processing serves compliance with youth-protection obligations (Art. 6(1)(c) GDPR). Facial data is processed by Yoti under its own privacy notice, available at yoti.com/privacy.

4.7 Content-Safety Analysis (Sightengine)

Uploaded images and videos are automatically analysed for prohibited content by Sightengine (Sightengine SAS, France) before they can be offered for sale. Files are transmitted for analysis and are not retained by Sightengine beyond the analysis. Legal basis: our legitimate interest in a lawful and safe platform (Art. 6(1)(f) GDPR) and compliance with card-scheme obligations.

4.8 Payment Processing

In addition to Stripe, card payments may be processed by a dedicated high-risk payment provider, and crypto payments by a third-party crypto payment service. These providers process the payment data they collect under their own privacy notices; Fangate receives the transaction status and billing country only.

5. Content Moderation

Uploads are screened with automated tools (hash matching, image and video safety analysis, and text filters) and, where flagged, reviewed by trained staff. No upload is permanently rejected solely by automated means: uploaders can reach human review of automated decisions. We keep moderation records (what was checked, the result, and the reviewer) to meet legal and card-scheme obligations. Legal basis: Art. 6(1)(c) and (f) GDPR.

6. Data of Depicted Persons (Consent Records)

Where a file shows a person other than the uploader, we process that person's data to document their consent: name, e-mail address, the consent declaration, and identity or age documents where provided. If the uploader requests consent from a person without a Fangate account, we send that person an invitation e-mail on the uploader's behalf. Consent records are retained for as long as the related content is offered and thereafter for the period required to demonstrate compliance. Legal basis: Art. 6(1)(c) and (f) GDPR. Depicted persons can exercise all rights listed in Section 3.

7. Contact Details

To contact us regarding data protection:
Controller: AA Consulting LLC, 1209 Mountain Road, Albuquerque, New Mexico 87110
Email: info@fangate.app