This Privacy Policy describes how Celebrity Response LLC ("Celebrity Response," "we," "us," or "our") collects, uses, discloses, and protects the personal information of users ("you" or "your") who access or use the Celebrity Response platform, including the website at https://celebrityresponse.app, the Celebrity Response iOS mobile application, and the Celebrity Response Android mobile application (collectively, the "Platform"). This Privacy Policy is incorporated into and forms part of our Terms of Service, available at https://celebrityresponse.app/help/privacy-policy

By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, you must not access or use the Platform.

The Platform serves two categories of users: general users who consume content, purchase subscriptions, send messages, and participate in live sessions ("Users"), and content producers who create, publish, and monetize content on the Platform ("Creators"). This Privacy Policy applies to both Users and Creators.

1. Information We Collect

We collect the following categories of personal information when you use the Platform:

1.1. Information You Provide Directly

(a) Account Information. When you register for an account, we collect your name, email address, username, password, profile photo, biography, and date of birth.

(b) Creator Information. If you register as a Creator, we additionally collect your legal name, physical address, tax identification information (including W-9 and 1099 data), bank account or payment account details for payouts, and any government-issued identification required for identity verification.

(c) Payment Information. When you make purchases on the Platform, including Credit purchases and in-app purchases through Apple App Store or Google Play Store, payment transactions are processed by our third-party payment processors. Celebrity Response does not directly store your full credit card numbers or financial account details. We receive transaction confirmation data including the amount, date, and a truncated payment method identifier. We also collect your Credit purchase and balance data, Deal request and transaction data, and in-app purchase records.

(d) Content and Communications. We collect the content you create, upload, or share on the Platform, including text posts, images, videos, audio recordings, music uploads, comments, direct messages, live session recordings, and Deal requests.

(e)Correspondence. If you contact us for support or other inquiries, we collect the content of your communications with us.

1.2. Information Collected Automatically

(a) Device and Usage Information. We automatically collect information about your device and how you interact with the Platform, including your IP address, browser type and version, operating system, device identifiers, referring URLs, pages visited, features used, timestamps, and interaction patterns.

(b) Location Information. We collect approximate location information derived from your IP address. We do not collect precise geolocation data unless you expressly consent to such collection.

(c) Cookies and Similar Technologies. We use cookies, pixels, web beacons, and similar tracking technologies to collect information about your browsing activity. See Section 10 of this Privacy Policy for details.

1.3.Biometric Information

We may collect biometric identifiers and biometric information as defined under applicable law, including the Illinois Biometric Information Privacy Act (BIPA). This includes:

(a) Facial Geometry. Facial geometry data derived from photographs and videos you upload or that are captured during live sessions on the Platform, which may be used for content features, filters, facial tagging, and identity verification.

(b) Voiceprints. Voiceprint data derived from audio and video content you upload or create on the Platform, which may be used for content features, audio processing, and identity verification.

For detailed information about our biometric data practices, including retention, consent, and your rights, see Section 5 of this Privacy Policy.

1.4. Information from Third Parties

We may receive information about you from third parties, including:

(a) social media platforms if you choose to link your account or log in using a third-party service;

(b) payment processors regarding the status of transactions;

(c) identity verification services used to confirm Creator identities; and

(d) analytics providers who help us understand Platform usage.

2. How We Use Your Information

We use the personal information we collect for the following purposes:

2.1. Platform Operations

(a) to create, maintain, and secure your account;

(b) to facilitate content creation, sharing, and consumption on the Platform;

(c) to process transactions including subscription payments, Credit purchases, message purchases, experience purchases, Deal requests, and in-app purchases processed through Apple App Store and Google Play Store;

(d) to process Creator payouts, commissions, and related financial transactions, including payouts generated through the Credit system and music streaming revenue;

(e) to administer the reward points system, including earning, tracking, and redemption of points;

(f) to facilitate Deal requests between Users and Creators, and to perform music streaming analytics and royalty calculations; and

(g) to enable live sessions, interactive features, and music streaming; and

(h) to send you transactional communications including purchase confirmations, payout notifications, and account alerts.

2.2. Improvement and Personalization

(a) to personalize your experience on the Platform, including content recommendations and Creator suggestions;

(b) to analyze usage trends and improve the functionality, performance, and design of the Platform;

(c) to conduct research and development for new features and services; and

(d) to perform analytics on aggregated and de-identified data.

2.3. Safety and Security

(a) to detect, prevent, and address fraud, unauthorized access, and other illegal or harmful activity;

(b) to verify user and Creator identities;

(c) to enforce our Terms of Service and other policies;

(d) to monitor content for compliance with our community guidelines; and

(e) to protect the rights, property, and safety of Celebrity Response, our users, and the public.

2.4. Legal Compliance

(a) to comply with applicable laws, regulations, and legal processes;

(b) to respond to lawful requests from government authorities;

(c) to fulfill tax reporting and withholding obligations, including the preparation and filing of IRS Forms 1099 for Creators; and

(d) to establish, exercise, or defend legal claims.

2.5. Communications

(a) to send you marketing and promotional communications about the Platform, subject to your right to opt out at any time; and

(b) to respond to your inquiries, feedback, and support requests.

3. Sharing of Information

We share your personal information in the following circumstances:

3.1. With Service Providers

We share information with third-party service providers who perform services on our behalf, including hosting and infrastructure providers, payment processors, analytics providers, customer support tools, email delivery services, and identity verification services. These providers are contractually required to use your information only for the purposes of providing services to Celebrity Response and in accordance with this Privacy Policy.

3.2. With Payment Processors

We share necessary transaction data with third-party payment processors, including Apple Inc. and Google LLC for in-app purchase processing, to facilitate purchases, subscriptions, Credit transactions, and Creator payouts. Payment processors are independent data controllers with respect to the payment data they process and are subject to their own privacy policies.

3.3. With Creators (Aggregated Analytics)

When you interact with, subscribe to, or make purchases from a Creator, that Creator may receive limited aggregated analytics about their subscribers and audience, including:

(a) view counts, engagement metrics such as likes, comments, and shares;

(b) subscriber demographic information presented in aggregate form, including age ranges and general geographic location (city or region level, not specific addresses or precise locations); and

(c) your subscription and purchase history with that specific Creator.

Creators do NOT receive your email address, phone number, payment card details, precise location, or other personal contact information through these analytics. By interacting with or subscribing to a Creator, you acknowledge that the Creator will receive the limited analytics described in this section.

3.4. With Other Users

Certain information you provide is visible to other users of the Platform based on your privacy settings, including your username, profile photo, biography, and any content you post publicly. See Section 4 for information about content visibility.

3.5. For Legal and Safety Purposes

We may disclose your information:

(a) to comply with applicable laws, regulations, or legal processes, including court orders and subpoenas;

(b) to respond to requests from law enforcement or government authorities;

(c) to protect the rights, property, or safety of Celebrity Response, our users, or the public;

(d) to enforce our Terms of Service and other agreements; and

(e) in connection with an investigation of suspected or actual fraud, illegal activity, or security threats.

3.6. Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or other corporate transaction involving Celebrity Response, your personal information may be transferred as part of that transaction. We will notify you of any such transfer and any choices you may have regarding your information.

3.7. With Your Consent

We may share your information with third parties when you have given us your explicit consent to do so.

3.8. No Sale of Personal Information

Celebrity Response does not sell your personal information to advertisers, data brokers, or other third parties. We do not share your personal information for cross-context behavioral advertising as defined under the California Consumer Privacy Act.

4. Content Visibility and Privacy Settings

4.1. Public Content

Content you post publicly on the Platform, including profile information, posts, comments, and other public interactions, is accessible to anyone on the internet, including people who do not have a Celebrity Response account. Public content may be indexed by search engines and may be shared, linked to, or embedded by third parties. You should not post content publicly that you wish to keep private.

4.2. Privacy Settings

The Platform provides privacy settings that allow you to control the visibility of certain content and profile information. You may adjust these settings at any time through your account settings. Available controls may include:

(a) setting your profile to public or restricted;

(b) controlling who can view specific posts or content;

(c) managing who can send you direct messages; and

(d) controlling visibility of your activity, such as likes and comments.

4.3. Direct Messages

Direct messages are private communications between the sender and the recipient. Celebrity Response does not make the contents of direct messages publicly available. However, we may access and review direct messages when necessary to enforce our Terms of Service, respond to legal processes, or investigate reports of harmful conduct.

4.4. Previously Distributed Content

If you change your privacy settings or delete content, previously distributed, cached, or shared versions of that content may remain accessible to those who accessed it prior to the change. Celebrity Response cannot guarantee complete removal of content that has already been distributed, shared, or indexed by third parties.

5. Biometric Data

This section provides important information about our collection and use of biometric data, including specific disclosures required under the Illinois Biometric Information Privacy Act, 740 ILCS 14 (BIPA), and other applicable biometric privacy laws.

5.1. Biometric Data We Collect

Celebrity Response may collect, capture, or otherwise obtain the following categories of biometric identifiers and biometric information:

(a) Facial Geometry. Scans of facial geometry derived from photographs and video content uploaded to the Platform or captured during live sessions. Facial geometry data may be used for content features (such as filters and effects), facial recognition for tagging suggestions, and identity verification for Creator accounts.

(b) Voiceprints. Voiceprint data derived from audio and video content uploaded to the Platform. Voiceprints may be used for audio processing features, content enhancement, and identity verification.

5.2. Purpose of Collection

We collect biometric data for the following specific purposes:

(a) to provide content features including photo and video filters, effects, and enhancements;

(b) to enable facial tagging and recognition features within the Platform;

(c) to verify the identity of Creators and users where required;

(d) to detect and prevent fraud, impersonation, and unauthorized access; and

(e) to improve the accuracy and quality of content-related features on the Platform.

5.3. Consent

Before collecting any biometric identifiers or biometric information, Celebrity Response will:

(a) inform you in writing (which may include electronic communication) that biometric data is being collected or stored;

(b) inform you in writing of the specific purpose and length of time for which your biometric data will be collected, stored, and used; and

(c) obtain your written release (which may include electronic consent through the Platform) authorizing Celebrity Response to collect and store your biometric data.

You may be presented with a biometric consent notice when you first use features that involve biometric data collection. Your use of biometric features after receiving and acknowledging such notice constitutes your written release under BIPA.

5.4. Retention and Destruction

Celebrity Response will retain your biometric data only until the earliest of:

(a) three (3) years from the date of your last interaction with the Platform;

(b) the date the initial purpose for collecting or obtaining the biometric data has been satisfied; or

(c) the date you request deletion of your biometric data.

Upon the occurrence of any of the above, Celebrity Response will permanently destroy your biometric data within thirty (30) days, provided that no valid legal requirement mandates further retention.

5.5. Disclosure and No Sale

Celebrity Response will not sell, lease, trade, or otherwise profit from your biometric data. We will not disclose your biometric data to any third party unless:

(a) you provide explicit consent to such disclosure;

(b) the disclosure completes a transaction that you requested or authorized;

(c) the disclosure is required by federal, state, or municipal law or ordinance, or by court order; or

(d) the disclosure is required pursuant to a valid warrant or subpoena.

5.6. Storage and Protection

Biometric data is stored using industry-standard security measures, including encryption at rest and in transit, access controls limiting access to authorized personnel, and regular security audits. Biometric data is stored with at least the same level of protection as other confidential and sensitive information maintained by Celebrity Response.

5.7. Right to Request Deletion

You may request the deletion of your biometric data at any time by contacting us at info@celebrityresponse.app. Upon receipt of a verified deletion request, we will permanently destroy your biometric data within thirty (30) days, subject to any applicable legal retention requirements.

6. Creator Data and Earnings Privacy

6.1. Confidentiality of Creator Financial Data

Celebrity Response treats all Creator financial information as confidential. This includes your payment account information, earnings history, payout records, commission statements, tax information (W-9 and 1099 data), and transaction-level revenue data.

6.2. Access to Creator Financial Data

Creator financial data is accessible only to:

(a) the Creator to whom the data pertains, through their Creator dashboard;

(b) Celebrity Response personnel who require access for legitimate business purposes, including payment processing, tax reporting, and account support; and

(c) third-party payment processors and tax reporting services to the extent necessary to process payouts and fulfill legal reporting requirements.

Creator financial data is not disclosed to other users, subscribers, other Creators, or the general public.

6.3. Security of Creator Financial Data

Creator financial data is protected by:

(a) encryption at rest and in transit using industry-standard encryption protocols;

(b) role-based access controls that restrict access to authorized personnel;

(c) regular security audits and monitoring for unauthorized access; and

(d) secure third-party payment processing infrastructure that complies with Payment Card Industry Data Security Standards (PCI DSS).

6.4. Creator Tax Information

Celebrity Response collects tax identification information from Creators solely for the purpose of complying with federal and state tax reporting obligations. Tax information is retained in accordance with Internal Revenue Service requirements and applicable state law, and is not used for any other purpose.

7. Security

7.1. Security Measures

Celebrity Response implements reasonable and appropriate technical, administrative, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:

(a) encryption of data in transit using Transport Layer Security (TLS) and at rest using industry-standard encryption;

(b) access controls and authentication mechanisms for systems that process personal information;

(c) regular security assessments and vulnerability testing;

(d) employee training on data protection and information security practices; and

(e) incident response procedures for addressing security events.

7.2. No Guarantee of Security

While we take reasonable measures to protect your information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of your personal information. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

7.3. Data Breach Notification

In the event of a data breach affecting your personal information, Celebrity Response will:

(a) notify affected individuals in accordance with Ohio Revised Code Section 1349.19 and any other applicable state breach notification laws;

(b) for users subject to the General Data Protection Regulation (GDPR), notify the relevant supervisory authority within seventy-two (72) hours of becoming aware of a breach that is likely to result in a risk to the rights and freedoms of natural persons, and notify affected individuals without undue delay where the breach is likely to result in a high risk; and

(c) take reasonable steps to mitigate the effects of the breach and prevent further unauthorized access.

8. Data Retention

8.1. General Retention Principles

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with our legal obligations, resolve disputes, and enforce our agreements. When determining retention periods, we consider:

(a) the nature and sensitivity of the information;

(b) the purposes for which the information is processed;

(c) applicable legal, regulatory, and contractual requirements; and

(d) legitimate business interests, including record-keeping and defense of legal claims.

8.2. Specific Retention Periods

(a) Account Data. We retain your account information for as long as your account remains active. If you close your account, we will retain your information for a period of up to three (3) years to comply with legal obligations, resolve disputes, and enforce our agreements, after which it will be securely deleted.

(b) Content. User-generated content associated with a closed account may be retained in anonymized or de-identified form. Content that was publicly available may continue to exist in cached or archived forms beyond our control.

(c) Creator Financial Data. Creator earnings records, payout history, and tax-related information are retained for a minimum of seven (7) years from the end of the applicable tax year, in accordance with Internal Revenue Service record retention requirements.

(d) Biometric Data. Biometric identifiers and biometric information are retained in accordance with Section 5.4 of this Privacy Policy.

(e) Transaction Records. Records of purchases, subscriptions, and payments are retained for a minimum of five (5) years from the date of the transaction.

(f) Communication Records. Direct messages and correspondence are retained for the duration of your account and for up to two (2) years following account closure.

8.3. Deletion

When personal information is no longer required for the purposes described above, we will securely delete or anonymize the information using commercially reasonable methods.

9. Your Rights

9.1. Rights for All Users

Regardless of your location, you may:

(a) access and review the personal information we hold about you through your account settings;

(b) update or correct inaccurate personal information through your account settings;

(c) close your account by contacting us at info@celebrityresponse.app; and

(d) opt out of marketing communications by using the unsubscribe link in any marketing email or by updating your communication preferences in your account settings.

9.2. Rights for California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA") provides you with additional rights regarding your personal information:

(a) Right to Know. You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which the information was collected, the business or commercial purpose for collecting the information, and the categories of third parties with whom we shared the information.

(b) Right to Delete. You have the right to request that we delete the personal information we have collected from you, subject to certain exceptions permitted by law.

(c) Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.

(d) Right to Opt-Out of Sale or Sharing. You have the right to opt out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising. As stated in Section 3.8, Celebrity Response does not sell your personal information or share it for cross-context behavioral advertising.

(e) Right to Limit Use of Sensitive Personal Information. You have the right to limit the use and disclosure of your sensitive personal information to purposes that are necessary to provide the services you have requested. Sensitive personal information we may collect includes biometric information and financial account information.

(f) Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA, including by denying you services, charging different prices, providing a different quality of service, or suggesting that you will receive a different level of service.

Categories of Personal Information Collected. In the preceding twelve (12) months, we have collected the following categories of personal information as defined by the CCPA: identifiers; personal information categories listed in California Civil Code Section 1798.80(e); characteristics of protected classifications under California or federal law (date of birth); commercial information; internet or other similar network activity; geolocation data (approximate); audio, electronic, visual, or similar information; professional or employment-related information (for Creators); and sensitive personal information (biometric data, financial account information).

Do Not Track Disclosure. The Platform does not currently respond to Do Not Track signals transmitted by web browsers. There is no uniform standard for how to respond to such signals, and we will continue to monitor developments regarding Do Not Track standards.

To exercise any of these rights, please contact us at info@celebrityresponse.app. We will verify your identity before processing your request. You may designate an authorized agent to submit a request on your behalf by providing the agent with written authorization.

9.3. Rights for EU/EEA Users (GDPR)

If you are located in the European Union or European Economic Area, the General Data Protection Regulation (GDPR) provides you with the following rights:

(a) Legal Bases for Processing. We process your personal data on the following legal bases:

(i) Contract Performance. Processing necessary for the performance of the contract between you and Celebrity Response (our Terms of Service), including account creation, content delivery, transaction processing, and Creator payouts.

(ii) Legitimate Interests. Processing necessary for our legitimate interests, including Platform security, fraud prevention, analytics and improvement of the Platform, and enforcement of our Terms of Service, provided that such interests are not overridden by your fundamental rights and freedoms.

(iii) Consent. Processing based on your freely given, specific, informed, and unambiguous consent, including the collection and processing of biometric data and the sending of marketing communications. You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

(iv) Legal Obligation. Processing necessary for compliance with a legal obligation to which Celebrity Response is subject, including tax reporting and responding to lawful government requests.

(b) Right of Access. You have the right to obtain confirmation as to whether your personal data is being processed and, where that is the case, access to the personal data together with specified supplementary information.

(c) Right to Rectification. You have the right to have inaccurate personal data rectified and, taking into account the purposes of the processing, to have incomplete personal data completed.

(d) Right to Erasure. You have the right to request the erasure of your personal data where one of the specified grounds under GDPR Article 17 applies, subject to applicable exceptions.

(e) Right to Restriction of Processing. You have the right to request the restriction of processing of your personal data in specified circumstances under GDPR Article 18.

(f) Right to Data Portability. You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller without hindrance.

(g) Right to Object. You have the right to object, on grounds relating to your particular situation, to processing of your personal data based on our legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defence of legal claims.

(h) Right to Withdraw Consent. Where processing is based on your consent, you have the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

(i) Right to Lodge a Complaint. You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of your personal data infringes the GDPR.

To exercise any of these rights, please contact us at info@celebrityresponse.app.

10. Cookies and Tracking Technologies

10.1. What Are Cookies

Cookies are small text files that are placed on your device when you visit a website. We also use similar technologies such as pixels, web beacons, and local storage.

10.2. Categories of Cookies We Use

(a) Essential Cookies. These cookies are strictly necessary for the operation of the Platform. They enable core functionality such as account authentication, security, and network management. You cannot opt out of essential cookies as the Platform cannot function without them.

(b) Analytics Cookies. These cookies help us understand how users interact with the Platform by collecting information about pages visited, features used, and general browsing patterns. Analytics data is aggregated and does not directly identify individual users.

(c) Functional Cookies. These cookies enable enhanced functionality and personalization, such as remembering your preferences, language settings, and display options.

(d) Advertising and Targeting Cookies. These cookies may be used to deliver relevant content and measure the effectiveness of our communications. We may use these cookies to understand your interests and show you relevant Creator recommendations.

10.3. Managing Cookies

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or alert you when a cookie is being set. Please note that disabling certain cookies may affect the functionality of the Platform.

10.4. Third-Party Analytics

We may use third-party analytics services, such as Google Analytics, to collect and analyze usage information. These services may use cookies and similar technologies to collect information about your use of the Platform. The information collected by these services is used to evaluate use of the Platform and compile reports on activity.

11. International Data Transfers

11.1. Data Processing Location

Celebrity Response is based in the United States, and your personal information is primarily processed and stored in the United States. If you access the Platform from outside the United States, your personal information will be transferred to and processed in the United States, which may have different data protection laws than your country of residence.

11.2. Transfers from the EU/EEA

For transfers of personal data from the European Union or European Economic Area to the United States, Celebrity Response relies on the following transfer mechanisms as appropriate:

(a) Standard Contractual Clauses (SCCs) as approved by the European Commission;

(b) your explicit consent to the transfer, where applicable; and

(c) any other legally recognized transfer mechanism under the GDPR.

11.3. Safeguards

Regardless of where your data is processed, we apply the same protections described in this Privacy Policy and implement appropriate technical and organizational measures to ensure an adequate level of protection for your personal data.

12. Children's Privacy

The Platform is intended exclusively for individuals who are eighteen (18) years of age or older, as set forth in our Terms of Service. Celebrity Response does not knowingly collect personal information from individuals under the age of eighteen (18). If we become aware that we have collected personal information from an individual under the age of eighteen (18), we will take steps to delete such information promptly. If you believe that we have inadvertently collected personal information from an individual under the age of eighteen (18), please contact us at info@celebrityresponse.app.

13. Changes to This Privacy Policy

Celebrity Response reserves the right to modify this Privacy Policy at any time. When we make material changes, we will:

(a) update the "Last Updated" date at the top of this Privacy Policy;

(b) post the revised Privacy Policy on the Platform; and

(c) provide notice through the Platform or by email for material changes.

Your continued use of the Platform following the posting of changes constitutes your acceptance of those changes. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Celebrity Response LLC

131 19th St

Toledo, Ohio 43604

Email: info@celebrityresponse.app

Website: https://celebrityresponse.app

For GDPR-related inquiries, you may also contact us at the email address above with the subject line "GDPR Request."

For CCPA-related requests, you may also contact us at the email address above with the subject line "CCPA Request."